A High Court hearing of contempt proceedings against Séan Quinn Snr and his son has now been adjourned for two weeks.
A new Belfast-based legal team asked the court for more time to prepare a defence for the former billionaire.
Ms Justice Elizabeth Dunne said it was up to the prison authorities to decide on Mr Quinn Jnr's release time as it was not a matter for the court.
A short time after the hearing, he was released and walked from the Four Courts with his wife and family, having served three months in Mountjoy Prison.
Lawyers for IBRC told the court there had still been no meaningful co-operation from Seán Quinn Snr to comply with court orders to reverse the asset-stripping of Quinn companies.
The court was told "nothing had been done and no steps had been taken".
Senior Counsel Paul Gallagher also wants the court to consider new evidence of control over companies previously denied by the Quinns.
Ms Justice Dunne described the new evidence as of great concern and told the Quinns' new legal team to concentrate on compliance issues rather than historical issues in the case.
Counsel for Mr Quinn Snr said his age and medical condition should be taken into account when punitive measures are being considered. However, he said Mr Quinn will say he has been co-operating fully and is willing to do more.
The Quinns have also written to IBRC asking if mediation would be possible in the case.
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