Opinion
14546-15 28751-15
09-20-2022
YA GLOBAL INVESTMENTS, LP F.K.A. CORNELL CAPITAL PARTNERS, LP, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
James S. Halpern, Judge
In these cases, we review notices of final partnership administrative adjustment in which respondent adjusted various partnership items reported by YA Global Investments, LP, for the calendar years 2006 through 2009. By order entered August 12, 2022, we presented the parties with questions that we wished to discuss with the parties' counsels and scheduled a conference hearing on Friday, September 16, 2022. The parties were not required to prepare written responses in advance of the hearing. The hearing was held as scheduled. While a transcript of the hearing will be produced, at the conclusion of the hearing the Court requested the parties to prepare and submit to the Court written summaries of their counsels' answers to the questions. In doing so, the parties may supplement the summaries with any additional information with respect to the questions that they wish the Court to consider. Although the Court expects the parties to address the questions addressed specifically to that party, the Court invites either party to address any of the questions. It is, therefore, ORDERED that the parties shall individually report to the Court as described above on or before November 16, 2022. It is further
ORDERED that, if a party wishes to address the report of the opposing party, the party shall ask leave to the Court no later than 10 days after service of the opposing party's report.