Opinion
16015-16
10-13-2022
GEM STATE SERIES OF FORTRESS INSURANCE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler, Judge
On January 4, 2022, and May 6, 2022, the parties filed joint status reports. The reports state how this case is related to two other cases, Docket Numbers 16016-16 and 16108-16, which involve a captive insurance transaction; this case and the related cases are being reassigned to new counsel for respondent; the parties have had substantial discussions regarding this case and the related cases; the parties agree to evaluate the ligated cases and re-engage in settlement discussions to try to resolve these cases or at least narrow the triable issues; and that the parties are requesting additional time to allow further engagement in settlement discussions and continue with discovery as necessary.
On October 6, 2022, the parties filed another joint status report. The report once again states there are two related cases, it indicates how there are nine small captive insurance cases which have been tried by the Tax Court, with four opinions having been rendered. The report also indicates how the parties will need significant time to prepare for trial, should settlement not be reached in this case.
In the October 6, 2022, status report the parties request that the Court order another joint status report within 150 days. Status reports in the other related cases, Docket Numbers 16016-16 and 16108-16, are due on November 28, 2022. In the forthcoming status report, and assuming a settlement is not reached, the parties are encouraged to outline their anticipated length of time need for discovery, and to propose mutually agreeable dates for trial and other corresponding deadlines.
Upon due consideration, it is
ORDERED that the parties shall file a joint report as to the then-present status of this case on or before January 13, 2023.