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Holly Garden Indem. Protected Cell v. Comm'r of Internal Revenue

United States Tax Court
Mar 1, 2022
No. 13968-20 (U.S.T.C. Mar. 1, 2022)

Opinion

13695-20 13701-20 13885-20 13899-20 13918-20 13956-20 13966-20 13968-20 14007-20 14897-20 14898-20 14987-20 15015-20 15017-20 15180-20 15214-20

03-01-2022

HOLLY GARDEN INDEMNITY PROTECTED CELL, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

James S. Halpern Judge

These cases are calendared for trial at the Court's April 11, 2022, Phoenix, Arizona, trial session.

Petitioners moved to consolidate and change place of trial. Respondent filed on January 14, 2022, in docket No. 14897-20 a motion for leave to file objection with a lodged objection. Pursuant to a teleconference with the parties on February 23, 2022, the Court will deny petitioners' motion to consolidate, as it does not encompass all of the cases. The Court on its own motion, with the agreement of the parties, will consolidate the above-docketed cases. The Court will deny petitioners' motion to change place of trial although the parties remain free at some later date to designate a new place or places of trial. The Court will deny respondent's motion for leave to file the objection in docket No. 14897-20. Therefore, it is

ORDERED that the motions to consolidate are granted, in that, all of the above-docketed numbers are consolidated for trial, briefing, and opinion. It is further

ORDERED that the motions to change place of trial are denied. It is further

ORDERED that respondent's January 14, 2022, motion for leave to file objection in docket No. 14897-20, is denied as moot. It is further

ORDERED that the above-docketed cases are continued, and are stricken for trial from the April 11, 2022, Phoenix, Arizona, trial session. It is further

ORDERED that these proceedings are stayed because the parties contemplate further consideration by the Internal Revenue Service Independent Office of Appeals. It is further

ORDERED that although all proceedings are stayed, the parties shall file with the Court, every 3 months commencing May 23, 2022, a report as to the then present status of the above cases.


Summaries of

Holly Garden Indem. Protected Cell v. Comm'r of Internal Revenue

United States Tax Court
Mar 1, 2022
No. 13968-20 (U.S.T.C. Mar. 1, 2022)
Case details for

Holly Garden Indem. Protected Cell v. Comm'r of Internal Revenue

Case Details

Full title:HOLLY GARDEN INDEMNITY PROTECTED CELL, ET AL., Petitioners v. COMMISSIONER…

Court:United States Tax Court

Date published: Mar 1, 2022

Citations

No. 13968-20 (U.S.T.C. Mar. 1, 2022)