Opinion
3823-19 4421-19
03-23-2023
ROYALTY MANAGEMENT INSURANCE COMPANY, LTD., ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge
These "micro-captive" insurance cases were tried between February 14 and 22, 2023, in Oklahoma City, Oklahoma. On December 15, 2022, petitioners filed, at docket entry # 78, the opening expert report and declaration of Brett Sanger, which did not include his signature. On January 24, 2023, respondent filed a Motion in Limine to exclude from evidence the opening report of Mr. Sanger. On February 14, 2023, we heard argument on the Motion. During argument, the Court noted certain errors in Mr. Sanger's opening report and struck several paragraphs from evidence. Accordingly, by Order served February 17, 2023, we granted in part and denied in part respondent's Motion to the extent outlined in the transcript of the proceeding.
All references to docket entries in this Order are to docket entries in the lead case, Royalty Management Insurance Company, Ltd. v. Commissioner, No. 3823-19.
On March 15, 2023, petitioners filed, at docket entry # 297, a document bearing the cover page "Report" consisting of a signed copy of Mr. Sanger's original opening report. At docket entry # 298, petitioners concurrently filed, under the caption "Report," a revised copy of Mr. Sanger's opening report, conforming to the Court's ruling at trial. Upon due consideration, it is
ORDERED that petitioners' document, filed March 15, 2023, at docket entry # 297 in docket number 3823-19, is recharacterized as First Amended Report. It is further
ORDERED that petitioners' document, filed March 15, 2023, at docket entry # 298 in docket number 3823-19, is recharacterized as Second Amended Report.