Opinion
13248-20
06-02-2023
SN WORTHINGTON HOLDINGS LLC F.K.A. JACOBS WEST ST. CLAIR ACQUISITION LLC, MM WORTHINGTON INC., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch Judge.
On June 1, 2023, the Court held a conference call with the parties to discuss the status of this case. Petitioner filed a status report on May 31, 2023, and raised a new issue regarding "whether any adjustments to the partnership's return can be made on the bases set forth in the FPAA in light of the Congressional requirement that the IRS audit SN Worthington under the BB A procedures." (BBA issue) To frame this issue for resolution, it is
ORDERED that Petitioner shall file an appropriate motion on the BBA issue by August 4, 2023. It is further
ORDERED that the Commissioner shall file a Response to the Petitioner's Motion by September 1, 2023. It is further
ORDERED that the Petitioner may file a Reply to the Commissioner's Response by September 15, 2023.