Opinion
18290-18 330-19
02-06-2023
ROBERT KNUDSEN AND ESTATE OF SHARON KNUDSEN, DECEASED, v. COMMISSIONER OF INTERNAL REVENUE, Respondent CHARLES W. BUCHTA, EXECUTOR, Petitioners
ORDER
Albert G. Lauber Judge
These "micro-captive" insurance cases involving petitioners' 2014-2016 tax years were assigned to the undersigned on June 14, 2022, for trial or other disposition. On January 27, 2023, the undersigned held an informal conference call with the parties to discuss possible trial dates. During the call, the parties agreed to a two-week special session beginning on March 18, 2024, at a time and place yet to be determined.
On February 2, 2023, respondent filed a Motion for Document Subpoena Hearing, requesting that these cases be calendared for a remote hearing solely to enable respondent to issue subpoena(s) returnable at that hearing. Petitioners have not expressly stated whether they object to the granting of this Motion.
The Court has scheduled a special hearing session each Wednesday specifically for the return of third-party subpoenas. We will add these cases to the Court's Wednesday, March 29, 2023, session. In consideration of the foregoing, it is
ORDERED that respondent's Motion for Document Subpoena Hearing is granted. It is further
ORDERED that these cases are scheduled for hearing on the status of the cases at the Court's March 29, 2023, Washington, D.C., special hearing session to be conducted remotely at a time certain of 1:00 p.m. (Eastern Time) on Wednesday, March 29, 2023, at which time any third-party subpoenas may be returnable. If all subpoenaed parties supply all subpoenaed documents to the requesting party in advance of the hearing, the hearing will be canceled. Special Trial Judge Panuthos will preside at the above-referenced hearing as previously assigned by Chief Judge. It is further
ORDERED that the Clerk of the Court shall serve on the parties a Notice of Remote Proceeding that shall contain comprehensive instructions on how to participate in the above-references remote proceeding. It is further
ORDERED that, no later than March 24, 2023, respondent shall file a status report advising the Court whether all third parties have complied with all subpoenas, so that a hearing is no longer necessary.