Opinion
10099-20
10-10-2023
SIH PARTNERS LLLP, EXPLORER PARTNER CORP., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler Judge.
On September 27, 2023, the Court held a third-party remote subpoena hearing for the return of third-party subpoenas issued by respondent in this case. At the hearing, the parties represented that third-party, Morgan Stanley, planned to make production of non-privileged documents but required additional time. Morgan Stanley further represented that further documents for production had been identified, and Morgan Stanley required additional time to review these documents before making production to respondent.
The parties agree that Morgan Stanley will provide the requested documents. During the hearing, the parties requested a joint extension of time to allow Morgan Stanley additional time to produce the documents.
Considering the foregoing, it is
ORDERED that, on or before October 25, 2023, the parties shall file a joint status report advising the Court whether all outstanding subpoenas have been complied with and whether an additional remote hearing is necessary.