Opinion
5924-21
06-20-2023
JITESH V. PATEL & SHITAL S. PATEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler, Judge
On June 12, 2023, the parties filed separate status reports informing the Court that additional time is needed to either resolve this case or narrow the issues presented to the Court considering the significant and complex issues a captive insurance case presents. The parties request an additional 90 days to file a status report.
The parties have not yet moved for consolidation but represent that they anticipate consolidating all related cases for trial, briefing, and opinion, if trial is necessary. The related cases that the parties identify are Docket Numbers: 11946-20, 5915-21, 31517-21, 31518-21, 23054-22, and 23055-22. Currently, Docket Numbers 31517-21, 31518-21, 23054-22, and 23055-22 are with the Independent Office of Appeals for settlement consideration.
Upon due consideration, it is
ORDERED that on or before September 12, 2023, the parties shall file with the Court a joint status report, or separate status reports if preferred, regarding the then-present status of this case.