Sirius XM Connected Vehicle Services Holdings Inc. and Subsidiaries f.k.a. Agero Holdings Inc. F.K.A. CCAS Holdings, Inc. and Subsidiaries Consolidated Group, Docket No. 17641-18, filed 10/22/19, has worked out a way to resolve most or all of the key issues in its current dust-up with IRS. And Judge Albert G (“Scholar Al”) Lauber is down with this.

Only I, an humble blogger, an outsider looking in, have got a question.

The parties think a motion for summary J would do it, and each party should make one. Only Sirius goes first, and when IRS responds, as Rule 121(b) mandates, IRS can cross-move for summary J.

Now it is well-known that I am a great fan of summary J, so much that I will not cross-reference all my blogposts wherein I waxed lyrical on the subject.

But cross-motion? The Rules never mention cross motions, although it would be a good thing if they did. Rule 121 seems to require separate motions, individually labeled.

But I applaud Judge Scholar Al for cutting through an ambiguity, even though he does so only in an order that cannot be used as precedent.