Opinion
11794-21
07-25-2024
RANCH SPRINGS, LLC, RANCH SPRINGS INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge.
On May 24, 2024, at docket entry #204, respondent filed a Motion in Limine to Exclude the Proposed Expert Rebuttal Report of Tim Finley (Finley Rebuttal Report). By Order served June 13, 2024, at docket entry #218, the Court indicated that it was inclined to strike some, but not all, of the Finley Rebuttal Report as a disguised affirmative opening report that was untimely filed. We stated that we would hear argument at trial regarding the portions of his report that are properly regarded as providing true rebuttal.
This case was called for trial at a special session of the Court beginning Monday, June 17, 2024, in Nashville, Tennessee. During the trial, the parties agreed upon appropriate redactions to the Finley Rebuttal Report. As thus redacted, the Finley Rebuttal Report was admitted into evidence as Exhibit 2011-P.
After due consideration, and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that respondent's Motion in Limine to Exclude the Proposed Expert Rebuttal Report of Tim Finley, filed May 24, 2024, at docket entry #204, is denied as moot.