Opinion
11587-20 30118-21
07-19-2023
SIRIUS SOLUTIONS, L.L.L.P., SIRIUS SOLUTIONS GP, L.L.C. TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge.
On July 18, 2023, the Commissioner filed a brief in support of motion for summary judgment [Doc. 71 and a motion for summary judgment [Doc. 72]. It appears that these documents were filed in error by the Commissioner since the documents reflect signatures by counsel for petitioner. We will strike these documents from the record.
"Doc." references are to the documents filed in the lead case, Docket No. 11587-20, as numbered by the Clerk of this Court.
Later that same day, the Commissioner filed a motion for partial summary judgment [Doc. 73] and a memorandum in support of motion for partial summary judgment [Doc. 74]. We will direct petitioner to file a response and the Commissioner to file a reply to petitioner's response. Accordingly, it is
ORDERED that the Commissioner's brief in support of motion for summary judgment [Doc. 71] is hereby deemed stricken from the Court's record. It is further
ORDERED that the Commissioner's motion for summary judgment [Doc. 72] is hereby deemed stricken from the Court's record. It is further
ORDERED that, on or before August 17, 2023, petitioner shall file a response to motion for partial summary judgment. It is further
ORDERED that, on or before September 7, 2023, the Commissioner shall file a reply to the petitioner's response to motion for partial summary judgment.