Opinion
3412-22
02-17-2023
SAVANNAH SHOALS, LLC, GREEN CREEK RESOURCES, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Joseph Robert Goeke Judge
On February 16, 2023, respondent filed a Motion to Supplement the Record and a Declaration of Thomas A. Gardella in Support of Motion to Supplement the Record. Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Supplement the Record is granted in that the Declaration of Thomas A. Gardella in Support of Motion to Supplement the Record shall be treated as a supplement to respondent's Motion for Partial Summary Judgment regarding respondent's compliance with the requirements of section 6751(b), filed January 25, 2023. It is further
ORDERED that the time in which petitioner has to respond to respondent's Motion for Partial Summary Judgment regarding respondent's compliance with the requirements of section 6751(b), filed January 25, 2023, is extended from February 27, 2023, to March 6, 2023.