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Piedmont Breeze, LLC v. Comm'r of Internal Revenue

United States Tax Court
Nov 2, 2022
No. 12011-20 (U.S.T.C. Nov. 2, 2022)

Opinion

12011-20

11-02-2022

PIEDMONT BREEZE, LLC, GREENCONE INVESTMENTS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Albert G. Lauber, Judge

This case is calendared for trial at a special session of the Court beginning on March 27, 2023, in Atlanta, Georgia. On October 31, 2022, the parties filed a joint status report in which they proposed a pre-trial schedule. Upon due consideration, it is

ORDERED that the parties are directed to adhere to the following pre-trial schedule:

(1) December 2, 2022: Last date to file any motions for summary judgment, including any motions for partial summary judgment;
(2) February 10, 2023: Last date to file any motions to compel discovery, motions for order to show cause under Tax Court Rule 91(f), motions to compel depositions of nonparty witnesses, motions to review the sufficiency of the answers or objections to requests for admissions, and motions for sanctions regarding responses to discovery and requests for admissions;
(3) February 17, 2023: Exchange expert witness reports and lodge them with the Court. Each expert witness report shall include a certification prepared by the witness that lists all documents and references such as books, articles, and other literature relied on to prepare the report and express the opinions therein. All documents and references described in the certification not previously exchanged by the parties, or that are not otherwise available commercially to the other party or in the public domain, shall be exchanged by this date;
(4) March 6, 2023: Pretrial memoranda shall be submitted to the Court and exchanged with the opposing party by this date. Each party's memorandum shall
identify all witnesses that the party may or will call and supply a brief summary of the anticipated testimony of each witness;
(5) March 10, 2023: Exchange any rebuttal expert witness reports and lodge them with the Court;
(6) March 13, 2023: Exchange and identify, in writing, any documents or materials that a party expects to use at trial (except solely for impeachment), but which are not stipulated;
(7) March 13, 2023: Last date to file a first stipulation of facts;
(8) March 13, 2023: Last date to file any motions in limine;
(9) March 20, 2023: Exchange any demonstrative exhibits that the parties intend to use in their opening statements.
(10) March 27, 2023: Trial expected to begin.

Any events not addressed in this Order will be governed by the timeframes set forth in the Tax Court Rules of Practice and Procedure.


Summaries of

Piedmont Breeze, LLC v. Comm'r of Internal Revenue

United States Tax Court
Nov 2, 2022
No. 12011-20 (U.S.T.C. Nov. 2, 2022)
Case details for

Piedmont Breeze, LLC v. Comm'r of Internal Revenue

Case Details

Full title:PIEDMONT BREEZE, LLC, GREENCONE INVESTMENTS, LLC, TAX MATTERS PARTNER…

Court:United States Tax Court

Date published: Nov 2, 2022

Citations

No. 12011-20 (U.S.T.C. Nov. 2, 2022)