Opinion
30615-21
03-22-2023
MICHAEL J. WATSON & TRACEY L. WATSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler, Judge.
The present case is related to five other cases currently pending before the Court. On March 14, 2023, the parties filed a joint status report which informs the Court that they anticipate filing a joint motion seeking consolidation of these cases for purposes of trial, briefing and opinion. The issues in this case include (1) whether the captive insurance companies qualify for an I.R.C. § 831(b) election in tax years 2015 through 2018, (2) whether the arrangement lacks economic substance, and (3) whether the arrangement constitutes insurance for federal income tax purposes. The report further states that the parties have been engaged in the process of document review and will soon begin informal discovery. Respondent has secured an expert witness. Respondent's administrative files, which are rather voluminous, are being scanned so that the documents can be provided to the expert and can be accessed by both of respondent's counsel who are in two different cities.
Given due consideration to the aforementioned, it is
ORDERED that on or before September 15, 2023, the parties shall file a joint report regarding the then-present status of this case. It is further
ORDERED that the telephone status conference (via Microsoft Teams) with the Court and the parties set for March 22, 2023, at 12:00p.m. (EST) to discuss the status of this case is no longer necessary and therefore cancelled.