Opinion
12384-20
03-29-2024
VALLEY PARK, LLC, REED OPPENHEIMER, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones Judge
Pursuant to the Court's Opinion (162 T.C. No. 6) issued in the above docketed case on March 28, 2024, it is
ORDERED that respondent's Motion for Partial Summary Judgment (Doc. 9) is denied. It is further
ORDERED that petitioner's Motion for Partial Summary Judgment (Doc. 16), is granted to the extent set forth in the Court's opinion. It is further
ORDERED that, on or before June 27, 2024, the parties shall file a status report (jointly if possible, otherwise separately) as to the readiness of the case for trial. In preparing the status report the parties shall advise the Court as to whether there are any current or anticipated discovery disputes. They shall likewise bear in mind the likelihood that the Court will hold partial trial on only the issue of valuation, with subsequent trial to follow only if necessary.