Opinion
5071-21
06-27-2023
SEABROOK PROPERTY, LLC, SEABROOK MANAGER, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro Judge
Upon due consideration, and for cause more fully appearing in the transcript of the hearing held on June 22, 2023, it is hereby
ORDERED that petitioner's Motion in Limine to Preclude Respondent from Raising New Issues (Doc. 101) is granted in part and denied in part in that respondent may raise at trial the section 170(e) issue discussed at the hearing, but respondent will have the burden of proof with respect to such issue.