Opinion
19469-21
04-08-2024
TWO CHIP, LLC, TWO CHIP INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge.
This case was on the Court's October 24, 2022 trial calendar for Atlanta, Georgia. It is a syndicated conservation-contribution case with a twist, however, in that it features a donation not of an easement, but of a fee-simple interest. Settling the case at IRS Appeals proved impossible, but the parties continue to try to settle at IRS Counsel. They recently reported that they continue to engage productively in informal discovery. This case can stay on a status-report track, and it is
ORDERED that on or before June 28, 2024 the parties shall file a joint status report describing their progress in settling the case or narrowing the issues to be tried.