Opinion
25197-16 15238-17 22729-17 11880-18
01-26-2023
JMPD Series of Fortress Insurance, LLC, et al., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge.
These microcaptive-insurance cases are on the Court's March 6, 2023 trial calendar for Dallas, Texas. They've been pending for years, and we spoke with the parties on January 25, 2023 to gauge progress. We learned that they have settled these cases, and are working to wrap up other tax years as well. The revenue agent helping respondent's counsel has informally asked for what is likely one last round of document production. Computations are likely to be difficult, but all agreed that there was no reason not to consolidate the cases and put them on a status-report track for now. It is therefore
ORDERED that these cases are consolidated for trial, briefing, and opinion. It is also
ORDERED that the parties' motions to continue these cases are granted in that they are stricken from the Court's March 6, 2023 trial calendar for Dallas, Texas. It is also
ORDERED that this division of the Court retains jurisdiction. It is also
ORDERED that on or before April 25, 2023 the parties shall submit settlement documents or file a status report describing their progress toward settlement.