Opinion
129-21
03-03-2022
Catherine E Carriere Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Mark V. Holmes, Judge
This case is on the Court's April 4, 2022 trial calendar for Los Angeles, California, and is mostly about the consequences of a tax-reduction transaction called the monetized installment sale. There is little or no law on this technique, but this case may not end up being the landmark in the field because Ms. Carriere died recently. In a phone call with the parties on March 2, the Court learned that they have been in touch but need first to tend to a couple motions. The first is to find a representative for Ms. Carriere's estate and get him substituted as a party. The second is to begin to assemble third-party records that would be useful in developing the case. Respondent will seek to use the Court's new subpoena hearings to start getting those records. All this will take some time, so it is
ORDERED that the parties' February 28, 2022 motion for continuance is granted in that this case is stricken from the Court's April 4, 2022 trial calendar. It is also
ORDERED that this division of the Court retains jurisdiction. It is also
ORDERED that on or before May 2, 2022 the parties shall file a status report to describe their progress in drafting motions to substitute parties and obtain third-party records. They should also include their very preliminary guesses as to the likelihood of trial, time to prepare for trial, and length of any trial.