Opinion
6267-12 6801-12 6835-12 6836-12 6837-12 6838-12 19246-12 13553-13.
10-27-2016
KEVIN A. SELLS, ET AL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
MARK V. HOLMES, JUDGE
These cases were called from the calendar at the Trial Session of the Court at Birmingham, AL on October 5, 2016 for trial. Counsel for petitioners made an oral motion to shift the burden of proof. Counsel for respondent appeared and objected to petitioners' oral motion. After due consideration and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that petitioners' oral motion to shift the burden of proof is granted, and respondent shall bear the burden of proof in these cases.
Dated: October 5, 2016