Opinion
18290-18 330-19
04-25-2023
ROBERT KNUDSEN AND ESTATE OF SHARON KNUDSEN, DECEASED, CHARLES W. BUCHTA, EXECUTOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
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. The parties have agreed to a two-week special trial session beginning Monday, March 18, 2024, with the venue to be determined. Petitioners designated Boise, Idaho, as their place of trial, and petitioner husband, because of his advanced age, has expressed a strong preference for holding the trial in Boise so as to minimize travel time. However, the Court does not have a designated courtroom in Boise, and it will not be possible to confirm, before December 2023, the availability of borrowed space in Boise.
On April 13, 2023, the undersigned held an informal conference call with the parties to discuss other possible trial venues. Respondent expressed a preference for trial in Reno, Nevada, where the Court has a designated courtroom. Petitioner's counsel continued to advocate for trial in Boise, but indicated that Reno would be the best second choice from the perspective of petitioner husband.
Balancing the competing factors, the Court concludes that the most prudent course is to set this case for a two-week trial in Reno beginning as previously agreed on March 18, 2024. In December 2023 the Court will check on the availability for that two-week period of borrowed courtroom space in Boise. If a suitable courtroom in Boise can be secured that will accommodate the electronic equipment needed for trial, the Court will discuss with the parties the desirability of shifting the place of trial back to Boise.
In consideration of the foregoing, it is
ORDERED that these cases are set for trial at a special session of the Court starting at 10:00 a.m., on Monday, March 18, 2024, in Room 1161, C. Clifton Young Federal Building and U.S. Courthouse, 300 Booth Street, Reno, Nevada, 89509. The undersigned will be presiding. The parties may file at their convenience a motion or a joint status report proposing a pre-trial schedule.
This order constitutes official notice of its contents to the parties.