Opinion
9152-21
09-14-2023
TOP ROCK BBS, LLC, BARNETT PROPERTIES, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda, Judge
On September 11, 2023, petitioner Top Rock BBS, LLC, Barnett Properties, Tax Matters Partner (Top Rock) filed a motion for partial summary judgment requesting that the Court find that the Commissioner failed to comply with I.R.C. section 6751(b). [Doc. 48.] The motion further indicated that the Commissioner objects to this motion. We will allow the Commissioner to file a response and Top Rock to file a reply to his response. Accordingly, it is
ORDERED that, on or before October 4, 2023, the Commissioner shall file a response to Top Rock's motion for partial summary judgment. It is further
ORDERED that, on or before October 25, 2023, Top Rock shall file a reply to the Commissioner's response to the motion for partial summary judgment.