Opinion
5848-20
11-15-2021
Michael J. Rogerson Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Emin Toro Judge.
This case was tried on May 5 and May 6, 2021, during the Court's Omaha, Nebraska, remote trial session and is now fully briefed. After review of the briefs, the Court wishes to have the parties' views on the impact of Treasury Regulation section 1.469-5(j) on the facts of this case. Upon due consideration, it is hereby
ORDERED that, on or before December 3, 2021, the parties shall file simultaneous supplemental briefs setting forth their views on the application (or not) of Treasury Regulation section 1.469-5(j) to the facts of this case. It is further
ORDERED that, on or before December 17, 2021, the parties shall file simultaneous supplemental reply briefs. 1