Opinion
7307-19
03-04-2022
Sand Investment Co., LLC, Inland Capital Management, LLC, Tax Matters Partner Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Albert G. Lauber, Judge.
On December 1, 2021, respondent filed a Motion for Partial Summary Judgment in this case. On January 28, 2022, petitioner filed an Objection to respondent's Motion and a Cross-Motion for Partial Summary Judgment. In consideration of the foregoing, it is
ORDERED that respondent shall file with the Court, on or before April 4, 2022, a response to petitioner's Cross-Motion for Partial Summary Judgment. In that document respondent shall also include any additional arguments that he wishes to make by way of reply to petitioner's Objection. We request that respondent include in his response an analysis of how the December 23, 2020, Findings of Fact and Conclusions of Law, entered by the Court of Common Pleas of Jasper County, South Carolina, affects this Court's consideration of the issues raised by the Cross-Motions for Partial Summary Judgment.