Buried in the Stygian cave of memory is the phrase “lives in being and twenty-one” but I’m not sure if that doesn’t refer to some casino and how long it will take to make up what I lost there or some legal principle from medieval England that got over here like an invasive species.
But whatever it was or is, Judge Courtney D. ()”CD”) Jones recalled it to life in Ronald A. Mitchell & Yohko T. Mitchell, et al., Docket No. 11869-20, filed 11/12/26.
Ron’s & Yo’s trusty attorney, whom I’ll call Bri, had worked a deal on an OIC-ETA with the IRS counsel originally on the case, using the deal from a prior case as a template. And filed same following template. Judge CD Jones remembers all that from a previous phoneathon.
Except.
Austin kicked same, and former IRS counsel left the IRS’ employ.
Bri does have another IRS attorney in the Mile High City who is more or less sympatico, so Judge CD Jones tells Bri to work with IRS.
“The Court has previously advised the parties of its concern about the age of these cases, corresponding lack of progress, and mistakes made and delays caused by the IRS. Likewise, the Court has previously expressed that it shares Mr. Mitchell’s concern regarding his advanced age and appreciates his desire to resolve this case during his lifetime. The Court reiterates those views. Accordingly, the Court strongly encourages the parties to use the November 13 meeting to find a path forward so that they can work expeditiously to resolve the case.
“Specifically, respondent’s prior counsel represented that the recently submitted OIC-ETA would receive expedited handling and that there was a reasonable chance that the case would be resolved by December 31, 2026. While the Court recognizes that there has been a change in respondent’s personnel, the Court nevertheless expects the parties to maintain fidelity to that timeline.” Order, at pp. 1-2. (Citations omitted).
And on or before 11/17/26 at 5 p.m. Eastern Time, report on progress.
Lives in being plus twenty-one years applies in Tax Court.
