Opinion
286-21
12-22-2023
CURTIS K. KADAU & LORI A. KADAU, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler, Judge
This case is set for trial, at a special trial session of the Court, commencing on February 20, 2024, in Tampa, Florida. On December 18, 2023, respondent filed a Motion for Partial Summary Judgment with respect to the issue of whether Risk and Asset Protection Services, Ltd. (Risk and Asset) was an insurance company for federal tax purposes. Respondent maintains in his motion, among other things, that Risk and Asset is not an insurance company because the purported reinsurance transactions between the Risk and Asset and R MC Property & Casualty, Ltd. did not transfer insurable risk and the transactions did not achieve insurable risk distribution.
Considering the foregoing, it is
ORDERED that on or before January 19, 2024, petitioners are to file a response to respondent's Motion for Partial Summary Judgment.