Opinion
14605-23
09-06-2024
WME LAND, LLC, OXFORD EXPLORATION GEORGIA, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
This case is currently calendared for trial during the Court's Birmingham, Alabama trial session, scheduled to begin October 15, 2024.
On August 21, 2024, the Commissioner filed a motion for entry of decision stating that the parties have reached a basis of settlement. The Commissioner's motion represents that Oxford Exploration Georgia, LLC as the Tax Matters Partner for WME Land, LLC agrees to the entry of the proposed stipulated decision, but does not certify that no party objects to the granting of the motion for entry of decision.
Rule 248(b), Tax Court Rules of Practice and Procedure, requires that the tax matters partner notify nonparticipating partners of the Commissioner's motion and that the Court allow 60 days for any partner to elect to intervene and object to entry of the proposed decision. If no partner intervenes, then the Court may enter the proposed decision. In consideration of the foregoing, it is
ORDERED that on or before October 21, 2024, any party who objects to the granting of the Commissioner's motion for entry of decision shall file (1) a motion for leave to file a notice of election to participate out of time and (2) a notice of election to participate. It is further
ORDERED that this case is stricken from the above-referenced trial session, and jurisdiction is retained by the undersigned.