With climate science mapping the retreat of glaciers, perhaps the old simile for slow progression should be retired. So I’ll propose “geological” for “glacial” to describe the pace of Possum Rock, LLC, Carrol Beavers, Tax Matters Partner, Docket No. 22637-22, filed 7/6/27.

This is a SCE from 2016 (pre-BBA), FPAA issued and petitioned in July, 2022. So we’re now four (count ’em, four) years into the process. A quick docket search reveals that two (count ’em, two) stips of fact and one of settled issues have so far been filed. So discovery should be about finished, right? After all, this Order says the case was set for trial in May, 2026 in Atlanta (except an Order dated 6/12/26 says May, 2027).

Not so fast, says Judge Morrison.

He lists fourteen (count ’em, fourteen) items, either facts or documents, unstiped and unprovided, which shall form a stipulation of (you should pardon the expression) basic facts. Like contracts of sale, deeds, reports, and what thereof was attached to the 1065 for year at issue. Of course, you might call the documents Proposed Trial Exhibits, but whatever the nomenclature, with a $19.8 million charitable deduction on the line and interest presumably running, y’all might want to put the pedal to the cliché.