Opinion
24165-22
05-22-2024
JOEL SPORN & ALISON ROBIN INGBER SPORN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler Judge.
On May 21, 2024, the parties filed a joint status report informing the Court that on January 31, 2024, petitioners had an initial settlement conference with respondent's Independent Office of Appeals ("Appeals") to discuss a possible resolution without the need for trial. The report also informs the Court that on April 12, 2024, Appeals sent petitioners' counsel a settlement proposal to resolve this case, however, on May 16, 2024, petitioners' counsel sent Appeals correspondence declining the proposed settlement and contacted respondent's counsel to inform him of the same.
This case is related to 5 other cases currently before this Court. The parties anticipate filing a Motion to Consolidate this case with the related cases for purposes of trial, briefing, and opinion. The parties also anticipate starting the informal discovery process in accordance with Branerton Corp. v. Commissioner, 61 T.C. 691 (1974); and retain multiple witness experts. This case involves micro-captive insurance transactions, which are significant, complex, and take time to prepare for trial. Accordingly, the parties propose to file another status report in 6 months.
Considering the foregoing, it is
ORDERED that on or before November 22, 2024, the parties shall file a joint status report informing the Court whether discovery in this case and the related cases have been completed or if further discovery is necessary; whether expert witnesses have been retained; the estimated length of trial; and otherwise address the parties' readiness for trial.