Five (count ’em, five) years post-petition and two (count ’em, two) years of faithful quarterly status reports which apparently show minimal progress towards resolution of Timothy Sod, LLC, Timothy Investors, LLC, Tax Matters Partner, Docket No. 12584-20, filed 11/14/25, Judge Christian N. (“Speedy”) Weiler confirms the pledge he made to Congress at his confirmation hearing “to decide all matters in an impartial manner, by applying the facts before me to the relevant provisions of the tax code and by also looking to controlling precedent.”
So he offers his aid to IRS counsel and to the Sods (a rather unfortunate moniker, obviously chosen by one happily unacquainted with coarse UK colloquialisms).
“The Court has identified these cases as possible conservation easement cases or syndicated conservation easement cases, and the Court is inclined to assist with the potential resolution of some or all issues in the case without the need for a trial.” Order, at p. 1.
Realizing that some words of the late President Reagan have lately become politically inflammatory internationally, I hesitate to quote any in this nonpolitical blog, but I respectfully suggest that counsels for both sides weigh each word of their responses to Judge Speedy Weiler’s following directive.
The parties shall meet and file a joint status report stating “(1) whether the parties have met and conferred, either in person or by telephone, to discuss the issues in dispute or alternatively whether this case remains under the IRS Independent Office of Appeals’ jurisdiction (Appeals); (2) should this case not remain with Appeals, the parties are to also address and inform the Court of the following: a. the specific issues in dispute, b. the efforts that the parties have undertaken or plan to undertake to settle this matter, c. whether this case is related to or analogous to one or more cases pending before this Court (or the United States Court of Appeals) and is therefore a good candidate for an agreement to abide or consolidation, and d. whether either party plans to file any pretrial or dispositive motion(s) and, if so, the nature of such motion(s).” Order, at p. 1.
And let the parties file a stip of settled issues, dealing with, inter alia (as my expensive colleagues would say) Boss Hossery and the usual Section 170 Dixieland Boondockery stuff.
Moreover, if all y’all (I’m getting ready for next month’s trip to TX) ask nicely, Judge Speedy Weiler will host a pretrial conference, be the same face-to-face or Zoomiegram, as the parties desire.
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