Opinion
11369-16 23895-16 24113-16 7434-17 14691-17 14692-17 3429-19
03-28-2023
CD LISTENING BAR, INC., ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber, Judge
These "micro-captive" insurance cases are calendared for trial during a special trial session beginning April 17, 2023, in Phoenix, Arizona. On March 24, 2023, respondent filed two Motions in Limine. The first Motion seeks to exclude from evidence certain information that petitioners failed to produce in discovery. The second Motion seeks to exclude a summary document from evidence because petitioners have "not provided the underlying documentation to support the summary in violation of F.R.E. 1006." Petitioners concurrently filed a Motion in Limine seeking to preclude respondent from raising new matters or (in the alternative) requesting an "order shifting the burden of proof with respect to the new matters to respondent."
Upon due consideration, it is
ORDERED that petitioners shall file, on or before April 7, 2023, a single response to respondent's Motions in Limine. It is further
ORDERED that respondent shall file, on or before April 7, 2023, a response to petitioners' Motion in Limine.