But Don’t Capitulate, Either

Judge Elizabeth A. (“Tex”) Copeland reiterates the advice of Judge David Gustafson to both sides in FBA St. Clair Property C, LLC, Jeffrey L. Smith, Partnership Representative, Docket No. 14406-23, filed 8/29/25. See my blogpost “Stipulate, Don’t Equivocate,” 11/2/23.

At least some of what the C-Clairs want could be stiped, but they’ve interlarded that with legal conclusions which IRS rightly disputes. Judge Tex Copeland won’t do the Matthew 3:12 number for the parties.

“Trial of this case is to begin in September 2025, and we expect comprehensive stipulations of fact continue to be filed before trial commences. The Court is not going to referee dueling proposed stipulations on a line-by-line basis. The Court expects the parties to confer in good faith and stipulate to all matters not reasonably in dispute.” Order, at pp. 2-3.

I’d quote more, but the Genius Baristas have again posted this Order in their impenetrable PDF, which I can’t drag-and-drop, so read for yourself.