If Justice Oliver Wendell Holmes, Jr., was the Yankee from Olympus, then Judge Elizabeth A. (“Tex”) Copeland is the Texan from the Temple, as she does the 1 Kings 3:16-28 number again on FBA St. Clair Property, LLC, Legacy Springs Development, LLC, Tax Matters Partner, Docket No. 17085-21, filed 9/8/25.

As she turned aside the C-Clairs’ objection to the Section 170(e) wildcard, so with the Legacy Springers’ objection; this case is stiped to follow C-Clair, so is bifurcated. Trial of Part Deux, which will feature Section 170(e), comes next year, with plenty of time for discovery.

As for bifurcation, while Joseph R. Willis & Guntas Matharu-Willis, Docket No. 20169-24S, filed 9/8/25 were headed for a single-track trial, Guntas’ motion to amend petition asking the Court to preserve petitioner’s recently-filed claim for relief pursuant to I.R.C. section 6015 caused STJ Jennifer E. (“Publius”) Siegel to ask Guntas and Joe to tell her if they want to bifurcate counsel.

“… we note that petitioners share a mailing address, and that practitioner PS has entered an appearance on behalf of both of them–an apparent conflict of interest.” Order, at p. 1. (Name omitted).

STJ Publius Siegel reminds PS that USTCPs are subject to Rule 24(g)(1), and therefore needs informed written consent from both Joe and Guntas to waive the obvious conflict of interest. Failing which, PS must bow out of one.

Guntas can lodge her proposed amendment, meantime both she and Joe need to bukh on the conflict and what IRS. thinks about it. And mail in their replies.