Green Rock LLC v. Internal Revenue Service et al
| Green Rock LLC |
| Internal Revenue Service, US Department of Treasury and United States of America |
| 2:2021cv01320 |
| October 2, 2021 |
| US District Court for the Northern District of Alabama |
| Annemarie Carney Axon |
| Administrative Procedure Act / Review or Appeal of Agency Decision |
| 05 U.S.C. § 702 Administrative Procedure Act |
| None |
Docket Report
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This docket was last retrieved on February 2, 2023. A more recent docket listing may be available from PACER.
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Filing 41
FINAL JUDGMENT Consistent with the Memorandum Opinion, the court GRANTS Plaintiff's #20 Motion for Summary Judgment, DENIES Defendants' #30 Motion for Summary Judgment, and SETS ASIDE the Notice 2017-10 for failure to comply with the Administrative Procedure Acts notice-and-comment requirement. Signed by Judge Annemarie Carney Axon on 2/2/2023. (KSS)
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Filing 40
MEMORANDUM OPINION. Signed by Judge Annemarie Carney Axon on 2/2/2023. (KSS)
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Filing 39
RESPONSE to re #38 Second Notice of Supplemental Authorities filed by Green Rock LLC. (Norris, Cameron)
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Filing 38
NOTICE of Supplemental Authority by Internal Revenue Service, US Department of Treasury, United States of America (Attachments: #1 Opinion in GBX Associates, LLC v. United States)(Causey, Daniel)
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Filing 37
RESPONSE to re #36 filed by Green Rock LLC. (Norris, Cameron)
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Filing 36
NOTICE of Supplemental Authority by Internal Revenue Service, US Department of Treasury, United States of America (Attachments: #1 Tax Court Opinion)(Causey, Daniel)
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Filing 35
REPLY Brief filed by Defendants Internal Revenue Service, US Department of Treasury, United States of America re: #30 Cross MOTION for Summary Judgment and Response to Plaintiff's Motion for Summary Judgment filed by Internal Revenue Service, US Department of Treasury, United States of America. (Causey, Daniel)
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Filing 34
REPLY Brief filed by Plaintiff Green Rock LLC re: #20 MOTION for Summary Judgment and Opposition to Defendant's Cross-Motion for Summary Judgment filed by Green Rock LLC. (Norris, Cameron)
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Filing 33
TEXT ORDER: The court GRANTS Plaintiff's consent motion for an extension of time. (Doc. #32 ). Plaintiff's combined reply and response is due on or before August 26, 2022. Defendant's reply is due on or before September 26, 2022. Signed by Judge Annemarie Carney Axon on 6/22/2022. (KEK)
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Filing 32
Consent MOTION for Extension of Time to File Response/Reply by Green Rock LLC. (Attachments: #1 Text of Proposed Order)(Norris, Cameron)
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Filing 31
Brief re #30 Cross MOTION for Summary Judgment and Response to Plaintiff's Motion for Summary Judgment . (Causey, Daniel)
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Filing 30
Cross MOTION for Summary Judgment and Response to Plaintiff's Motion for Summary Judgment by Internal Revenue Service, US Department of Treasury, United States of America. (Causey, Daniel)
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Filing 29
TEXT ORDER granting Defendants' #28 unopposed motion for an extension of the page limitations. Defendants' consolidated response brief and cross-motion for summary judgment may not exceed 42 pages. Signed by Judge Annemarie Carney Axon on 6/8/2022. (RLW)
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Filing 28
Consent MOTION for Leave to File Excess Pages by Internal Revenue Service, US Department of Treasury, United States of America. (Causey, Daniel)
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Filing 27
SUPPLEMENTAL Evidentiary Submission re: #20 MOTION for Summary Judgment . (Norris, Cameron) Modified on 5/11/2022 (KEK).
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Filing 26
TEXT ORDER granting Defendants' #25 consent motion for an extension of the briefing schedule. Defendants' response and cross-motion for summary judgment is now due on or before June 13, 2022. Plaintiff's combined reply and response to the cross-motion is due on or before July 12, 2022. Defendants' reply is due August 10, 2022. Signed by Judge Annemarie Carney Axon on 5/9/2022. (RLW)
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Filing 25
Consent MOTION for Extension of Time to File Response/ Motion for Summary Judgment by Internal Revenue Service, US Department of Treasury, United States of America. (Causey, Daniel)
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Filing 24
TEXT ORDER: The court GRANTS #23 Amended Motion for Leave to Appear pro hac vice for attorney Frank H. Chang contingent upon payment of the $75.00 pro hac vice fee within 7 days of entry of this order. The court FINDS AS MOOT #19 Motion for Leave to Appear with the filing of #23 Amended Motion. Signed by Judge Annemarie Carney Axon on 5/5/22.(SAC)
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PHV Fee paid: $ 75, receipt number AALNDC-4080649 (ALND B4601120081). (Norris, Cameron) Modified on 5/6/2022 (KEK).
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Filing 23
MOTION for Leave to Appear Pro Hac Vice Amended Application for Pro Hac Vice Admission of Frank H. Chang by Green Rock LLC. (Neiman, John)
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Filing 22
Brief re #20 MOTION for Summary Judgment filed by Green Rock LLC. (Norris, Cameron)
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Filing 21
Evidentiary Material re: #20 MOTION for Summary Judgment . (Norris, Cameron)
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Filing 20
MOTION for Summary Judgment by Green Rock LLC. (Norris, Cameron)
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Filing 19
MOTION for Leave to Appear pro hac vice as to Frank H. Chang by Green Rock LLC. (Attachments: #1 Exhibit Declaration)(Norris, Cameron)
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Filing 18
STATUS REPORT (Joint) by Internal Revenue Service, US Department of Treasury, United States of America. filed by Internal Revenue Service, US Department of Treasury, United States of America (Causey, Daniel)
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Filing 17
NOTICE by Internal Revenue Service, US Department of Treasury, United States of America of Filing of Administrative Record (Attachments: #1 Certification of Administrative Record, #2 Index of Administrative Record, #3 Record pp. 1-200, #4 Record pp. 201-400, #5 Record pp. 401-600, #6 Record pp. 601-700, #7 Record pp. 701-805)(Causey, Daniel)
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Filing 16
SCHEDULING ORDER: The parties are to file the administrative record by March 4, 2022. The parties shall file a joint status report on or before March 7, 2022. No causes of action, defenses, or parties may be added after March 14, 2022 as to plaintiff and March 24, 2022 as to defendants. Discovery commences one day after the administrative record is filed and concludes on April 4, 2022. Green Rock will file a motion for summary judgment by April 15, 2022. The Government will file a combined response and cross-motion for summary judgment 30 days after service of Green Rock's motion. Green Rock will file a combined response and reply 21 days after service of the Government's combined response and cross-motion. The Government will file a reply 21 days after service of Green Rock's combined response and reply. Signed by Judge Annemarie Carney Axon on 2/18/2022. (KEK)
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Filing 15
REPORT of Rule 26(f) Planning Meeting. (Norris, Cameron)
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Filing 14
INITIAL ORDER GOVERNING ALL FURTHER PROCEEDINGS - with appendices attached. Signed by Judge Annemarie Carney Axon on 1/20/22. (SAC)
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Filing 13
ANSWER to #1 Complaint by Internal Revenue Service, US Department of Treasury, United States of America.(Causey, Daniel)
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Filing 12
TEXT ORDER granting Defendants' #11 consent motion for an extension of time to file a responsive pleading. Defendants' responsive pleading is now due on or before January 20, 2022. Signed by Judge Annemarie Carney Axon on 12/3/2021. (RLW)
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Filing 11
Consent MOTION for Extension of Time to File Answer re #1 Complaint by Internal Revenue Service, US Department of Treasury, United States of America. (Causey, Daniel)
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Filing 10
RETURN OF SERVICE by Green Rock LLC re #9 Summons Issued as to USA (Neiman, John)
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Filing 9
Summons Issued as to Internal Revenue Service, US Department of Treasury, United States of America, U.S. Attorney and U.S. Attorney General. Returned to Plaintiff for service. (KEK)
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Filing 8
TEXT ORDER - Per the filing of #4 and #5 Amended Motions for Leave to Appear Pro Hac Vice, the court FINDS AS MOOT #2 and #3 Motions for Leave to Appear Pro Hac Vice. Signed by Judge Annemarie Carney Axon on 10/5/21. (SAC)
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Filing 7
TEXT ORDER: The court GRANTS #5 Motion for Leave to Appear pro hac vice for attorney Cameron T. Norris contingent upon payment of the $75.00 pro hac vice fee within 7 days of entry of this order. Signed by Judge Annemarie Carney Axon on 10/5/. (SAC)
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Filing 6
TEXT ORDER: The court GRANTS #4 Motion for Leave to Appear pro hac vice for attorney Patrick Strawbridge contingent upon payment of the $75.00 pro hac vice fee within 7 days of entry of this order. Signed by Judge Annemarie Carney Axon on 10/5/21. (SAC )
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Filing 5
MOTION to Amend/Correct #3 MOTION for Leave to Appear pro hac vice by Green Rock LLC. (Attachments: #1 Supplement Declaration)(Neiman, John)
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Filing 4
MOTION to Amend/Correct #2 MOTION for Leave to Appear pro hac vice by Green Rock LLC. (Attachments: #1 Supplement Declaration)(Neiman, John)
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PHV Fee paid: $ 75, receipt number 1126-3938249. (Norris, Cameron)
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PHV Fee paid: $ 75, receipt number 1126-3938257. (Strawbridge, Patrick)
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Filing Fee: Filing fee $ 402, receipt_number 1126-3938514. related document #1 COMPLAINT against Internal Revenue Service, US Department of Treasury, filed by Green Rock LLC. (Attachments: # 1 Exhibit A)(KEK). (Neiman, John)
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Filing 3
MOTION for Leave to Appear pro hac vice as to Cameron T Norris by Green Rock LLC. (KEK)
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Filing 2
MOTION for Leave to Appear pro hac vice as to Patrick Strawbridge by Green Rock LLC. (KEK)
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Filing 1
COMPLAINT against Internal Revenue Service, US Department of Treasury, filed by Green Rock LLC. (Attachments: #1 Exhibit A)(KEK)
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