Opinion
12214-20
06-05-2023
TOSCANO HOLDINGS, LLC, TOSCANO INVESTMENTS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris Judge
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 of Michelle Levin in Support of Motion to Invalidate the Final Partnership Administrative Adjustment and Incorporated Memorandum of Law, docket entry 33.
By Order dated May 23, 2023, docket entry 39, the Court extended the time in which respondent must file a response to petitioner's above-referenced Motion to June 16, 2023.
The Court will set this case for Hearing on petitioner's Motion to Invalidate the Final Partnership Administrative Adjustment and Incorporated Memorandum of Law, and respondent's response thereto, to be filed on or before June 16, 2023, at the Birmingham, Alabama remote Special Trial Session commencing on Tuesday, June 20, 2023. The Court will schedule the Hearing for a date and time certain of Thursday, June 22, 2023, at 9:00 a.m. CT (10:00 a.m. ET).
After due consideration, it is
ORDERED that this case is set for Hearing on petitioner's Motion to Invalidate the Final Partnership Administrative Adjustment and Incorporated Memorandum of Law, and respondent's response thereto, to be filed on or before June 16, 2023, at the Court's Birmingham, Alabama remote Special Trial Session commencing on Tuesday, June 20, 2023, for a date and time certain of Thursday, June 22, 2023, at 9:00 a.m. CT (10:00 a.m. ET), where Birmingham, Alabama shall be listed as the place of trial for this remote Special Session. It is further
ORDERED that the Clerk of the Court shall also serve on the parties a Notice of Remote Proceeding that shall contain comprehensive instructions on how to participate in the above-referenced remote proceeding.