Opinion
11587-20 30118-21
12-01-2023
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 partial motion for summary judgment. Subsequently, on September 7, 2023, petitioner Sirius Solutions, L.L.L.P., Sirius Solutions GP, L.L.C., Tax Matters Partner (Sirius Solutions) filed a motion for summary judgment.
On November 28, 2023, the Court issued a precedential opinion in Soroban Capital Partners LP v. Commissioner, Nos. 16217-22, 16218-22, 161 T.C., (Nov. 28, 2023). It would be helpful to our resolution of the pending motions for the parties to address Soroban and its effect (if any) on the arguments previously presented. Accordingly, it is
ORDERED that, on or before December 21, 2023, the parties shall file separate status reports no longer than 15 pages regarding the import of Soroban.