Opinion
7768-19 11880-19
10-04-2023
EVOLUTION INSURANCE COMPANY, INC., ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge
On September 27, 2023, the parties filed a joint status report in these consolidated cases. The parties note that these cases are related to three other cases that have been referred to the IRS Independent Office of Appeals. If petitioners are able to reach a settlement in those cases, it is likely that the settlement will serve as a potential basis for resolution of the years at issue in these cases. In addition, the parties have executed, with respect to one or more issues involved in the instant cases, an agreement to be bound by the resolution of certain issues litigated in Patel v. Commissioner, Docket Nos. 24344-17, 11352-18, and 25268-18, which are currently pending before another Division of this Court. In consideration of information contained in the report, it is
ORDERED that the parties shall file with the Court a joint status report regarding the then-present status of these cases by March 28, 2024, or within 30 days after issuance of an opinion in Patel v. Commissioner, whichever first occurs.