Opinion
9517-19
11-16-2021
The Sing Resettlement, Line Trust Corporation, LTD., Trustee Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Albert G. Lauber Judge
On December 1, 2020, respondent filed a Motion for Partial Summary Judgment with respect to two of the issues in this case: (1) for 2012 and 2013, whether petitioner is disqualified from electing to include capital gain income in net investment income, and therefore precluded from deducting investment interest, because it did not timely file its returns for those years; and (2) for 2012, whether petitioner's income from SL Willy LLC should be treated as "active" rather than "passive," so that petitioner is precluded from offsetting that income with passive activity losses.
On January 21, 2021, petitioner filed a response stating that it does not op pose the granting of respondent's Motion for Partial Summary Judgment. We will therefore grant the Motion. However, other issues appear to remain in dispute, so we will ask the parties to file a status report expressing their views as to the con - duct of further proceedings in this case. It is accordingly
ORDERED that respondent's Motion for Partial Summary Judgment, filed December 1, 2020, is granted. It is further
ORDERED that, on or before December 15, 2021, the parties shall file a status report (jointly if possible, otherwise separately) expressing their views as to the conduct of further proceedings in this case.