Opinion
25431-16 22360-17 15093-18 19528-19
02-10-2023
Harold R. Bowser, Jr. & Debra L. Bowser, et. al, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge.
These microcaptive-insurance cases are on the Court's March 6, 2023 trial calendar for Dallas, Texas. They've all been continued before and on January 27, 2023 the parties moved to continue them again. We spoke with the parties on February 9, 2023 to gauge progress and discuss a way forward. All agreed that these are Artex microcaps without a reinsurance pool and that the same issues are present in three later years involving the same taxpayers that will likely be in Exam till late this year.
The parties were not able to settle at IRS Appeals, but have not given up on settling the cases without the months of pretrial preparation it would take to get them ready for trial. The Court agrees that it makes the most sense now to encourage the parties to continue with informal discovery to make a better informed estimate of whether the cases are headed to settlement or need to be put under a pretrial order. It is therefore
ORDERED that the above-docketed cases are consolidated for trial, briefing, and opinion. It is also
ORDERED that the parties' January 27, 2023 motions for continuance are granted in that these cases are stricken from the Court's March 6, 2023 trial calendar for Dallas, Texas. It is also
ORDERED that this division of the Court retains jurisdiction. It is also
ORDERED that on or before June 8, 2023 the parties shall file a status report describing their progress toward settlement in these and later years.