Opinion
11946-20
04-21-2023
AMAYA INSURANCE COMPANY, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler, Judge
On March 17, 2023, respondent filed a status report in this matter. In the status report, respondent advised the Court that this case involves captive insurance issues for years 2014, 2015 and 2016. Respondent also advised the Court that there are related cases involving this petitioner for tax year 2017, which are currently pending before the Independent Office of IRS Appeals. Respondent's status report also advises in "the event a settlement cannot be reached, the parties will require significant time to engage expert witnesses, conduct discovery, and prepare for trial. It has been the experience of the parties that these cases require approximately one week of trial time." Respondent requested that another status report be due in 150 days. No status report was received from petitioner.
Considering the foregoing, it is
ORDERED that on or before July 26, 2023, the parties shall file a proposed stipulated decision or file a status report (joint or separate, if preferred) informing the Court of the then-present status of this case.