Opinion
11794-21
11-15-2022
RANCH SPRINGS, LLC, RANCH SPRINGS INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
On November 10, 2022, the Commissioner filed a motion for partial summary judgment regarding the issue of whether the conservation easement has satisfied the requirements of I.R.C. section 170 and the attendant Treasury Regulations. We will direct petitioner Ranch Springs, LLC, Ranch Springs Investors, LLC, Tax Matters Partner (Ranch Springs) to file a response to the motion. Accordingly, it is
ORDERED that, on or before December 14, 2022, Ranch Springs shall file a response to the Commissioner's motion for partial summary judgment.