Opinion
8390-19 8391-19 8407-19
10-04-2023
ANTHONY J. BUSA & REBECCA S. BUSA, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
L. PAIGE MARVEL JUDGE
These consolidated cases involve a captive insurance agreement for taxable years 2012 and 2013. On September 29, 2023, the parties filed a Joint Status Report stating, among other things, that the parties believe they have informally reached a settlement in these cases. Respondent's revenue agent is working on the required calculations and the preparation of Forms 906, Closing Agreement on Final Determination Covering Specific Matters, to be executed by the parties. The parties request additional time to prepare and execute the Forms 906 and to settle these cases. Upon due consideration, it is
ORDERED that on or before March 4, 2024, the parties shall file with the Court a proposed stipulated decision in each of these cases. If the proposed stipulated decisions are not available by March 4, 2024, the parties shall file a joint status report regarding the then-present status of these cases.