Judge Christian N. (“Speedy”) Weiler belies his cognomen as he puts the brakes on Brank Cove Capital, LLC, Gene Larson, Tax Matters Partner, Docket No. 12074-20, filed 6/17/25. After the trial, which is virtually a petitioner’s laydown, just as IRS was lining up the 40% substantial overvaluation chop, petitioner’s trusty attorneys trotted out the Seventh and Eighth Amendment jury trial and excessive fines argument.

“Petitioner also cites to a case pending before then United States Court of Appeals for the Eleventh Circuit dealing with this issue. As previously noted, the Court also has a case pending in which the same or similar issue has been raised. At the suggestion of petitioner, we are inclined to await entering a decision in this case and allow the parties to submit post-trial briefing on this legal issue—should they choose to do so. Accordingly, we will not enter a Decision at this time.” Order, at p. 1.

So let the parties file some status reports.