Opinion
7307-19
12-27-2021
Sand Investment Co., LLC, Inland Capital Management, LLC, Tax Matters Partner Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Albert G. Lauber, Judge
On December 1, 2021, respondent filed a motion for partial summary judg ment addressing the question whether the deed of conservation easement fails to satisfy the perpetuity requirements of I.R.C. §§ 170(h)(2)(C) and 170(h)(5)(A). We directed petitioner to file a response to respondent's motion on or before Jan uary 4, 2022. On December 22, 2021, petitioner filed a Motion for Extension of Time, requesting until January 21, 2022, to file its response. Re spondent does not object to the granting of this Motion. In consideration of the foregoing, it is
ORDERED that petitioner's Motion for Extension of Time, filed December 22, 2021, is granted in that the time within which petitioner shall respond to re spondent's motion for partial summary judgment is extended to January 21, 2022.