Opinion
10748-20
07-07-2022
WALKER DRIVE DEVELOPMENT PARTNERS LLC, WALKER DRIVE MANAGER LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth A. Copeland Judge
On July 1, 2022, pursuant to Tax Court Rule 141(a), respondent filed a Motion to Consolidate Docket Numbers 10748-20, 11677-20, 11813-20, 12184-20, 5256-21, 6426-21. Therein, respondent moves for the Court to consolidate the above-captioned case for purposes of trial, briefing, and opinion with the cases at Docket Nos. 11677-20, 11813-20, 12184-20, 5256-21, and 6426-21 on the grounds that these cases share common facts and legal issues and consolidating these cases will eliminate repetitive testimony and conserve the time of the Court, the parties, and the witnesses. Respondent states in the motion that the aforementioned Docket Nos. requested different locations for place of trial. Docket No. 12184-20 requested trial in Jacksonville, Florida; Docket No. 11813-20 requested trial in Nashville, Tennessee; and Docket No. 11677-20 requested trial in Tampa, Florida. The above-captioned case, along with Docket Nos. 5256-21 and 6426-21, all requested their trials to be held in Atlanta, Georgia.
In the motion, respondent states that petitioner objects to the granting of the motion and that respondent is filing this motion because the parties were unable to agree upon the language of a joint motion.
After due consideration, and for cause, it is
ORDERED that, on or before July 28, 2022, petitioner shall file a response to respondent's July 1, 2022, Motion to Consolidate Docket Numbers 10748-20, 11677-20, 11813-20, 12184-20, 5256-21, 6426-21 for Trial, Briefing, and Opinion.