Opinion
12584-20
07-26-2022
TIMOTHY SOD, LLC, TIMOTHY INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler Judge
This case is calendared for trial on the Court's Atlanta, Georgia trial session beginning on November 28, 2022. On July 25, 2022, petitioner filed a Motion for Continuance of Trial. This case involves the denial by respondent of a charitable deduction arising from the donation by Timothy Sod, LLC of a conservation easement, and the assertion of penalties under sections 6662 and/or 6662(a). The issues involve testimony by expert witnesses and additional factual development. The IRS Independent Office of Appeals has contacted petitioner, but petitioner has not yet had an opportunity to have a conference with the IRS Independent Office of Appeals. Petitioner requests that this motion be granted and this case be continued and Judge Weiler retain jurisdiction of this case. Respondent does not object to the granting of this motion.
Upon due consideration, it is
ORDERED that petitioner's Motion for Continuance is granted and this case is stricken for trial from the November 28, 2022, Atlanta, Georgia trial session and is continued. It is further
ORDERED that the undersigned retains jurisdiction over this case. It is further
ORDERED that on or before January 20, 2023, the parties shall file a joint report regarding the then-present status of the case.