Opinion
12214-20
05-18-2023
TOSCANO HOLDINGS, LLC, TOSCANO INVESTMENTS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris Judge
On March 7, 2023, docket entry 31, the parties filed a Joint Status Report indicating that this case had been closed out of the IRS Independent Office of Appeals (or would be closed out shortly) and returned to the IRS Office of Chief Counsel for trial preparation. The Joint Status Report also stated that with the Court's approval, the parties would submit a Proposed Stipulated Decision or a Joint Status Report on or before June 5, 2023. The Court will direct the parties to file a Proposed Stipulated Decision or a Joint Status Report on or before June 5, 2023.
On April 25, 2023, petitioner filed a Motion to Invalidate the Final Partnership Administrative Adjustment and Incorporated Memorandum of Law, docket entry 32, and a declaration from Michelle Levin in support of that Motion, docket entry 33. The Court will direct respondent to file a response to petitioner's current Motion, docket entry 32, in fourteen (14) days.
After due consideration, and for cause, it is
ORDERED that, on or before May 31, 2023, respondent shall file a response to petitioner's Motion to Invalidate the Final Partnership Administrative Adjustment and Incorporated Memorandum of Law, filed April 25, 2023, docket entry 32. It is further
ORDERED that, on or before June 5, 2023, the parties shall submit a Proposed Stipulated Decision or file a Joint Status Report as to the then-present status of this case.