Opinion
20849-17
05-25-2023
ST. ANDREWS PLANTATION, LLC, JOSEPH N. MCDONOUGH, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
David Gustafson Judge
Petitioner filed a motion (Doc. 98) for a protective order, asking the Court to impose certain restrictions on Respondent's contacts with non-participating partners of the TEFRA suit at issue in this case. We held a telephone conference with the parties, during which we made suggestions to the parties about actions they might agree on, and we set a schedule for further filings (embodied in Doc. 99)--but with the expressed hope that the parties might resolve the discovery dispute on their own. They did so, and on May 24, 2022, they filed a joint stipulation (Doc. 100), describing their agreement and providing (as Exhibit A, also attached hereto) a copy of a letter format that Respondent will use in his written contacts. We appreciate the work of the parties in coming to this agreement. It is
ORDERED that the parties need not make the additional filings directed in Doc. 99. It is further
ORDERED that petitioner's motion (Doc. 98) is granted to the extent provided in the stipulation (Doc. 100). It is further
ORDERED that the Clerk of the Court shall attach to this order a copy of Exhibit A to the joint stipulation (Doc. 100).