Opinion
7307-19
11-19-2021
Sand Investment Co., LLC, Inland Capital Management, LLC, Tax Matters Partner Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
ALBERT G. LAUBER JUDGE
On November 17, 2021, the parties filed separate status reports. Petitioner requests that the Court set this case for trial in Atlanta, Georgia, starting June 6, 2022. Respondent believes that it is premature to set this case for trial, given the pendency of the cross-motions for partial summary judgment on the I.R.C. § 6751(b) issue. Respondent also represents that he intends to file a motion for partial summary judgment under I.R.C. § 170(h)(5)(A). We agree with respondent that setting the case for trial at this time is premature.
In consideration of the foregoing, it is
ORDERED that the parties shall file with the Court, on or before January 19, 2022, a status report (jointly if possible, otherwise separately) detailing the then-present status of the case.