Opinion
14076-16 12155-17 12156-17 5890-18 5891-18 9997-19 9998-19 10133-20 10134-20 10260-21 10262-21 11717-22 15764-23 15765-23
07-22-2024
MITCH LANGSTEIN & PAULA LANGSTEIN, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch Judge
These cases are calendared for trial beginning on January 6, 2025, in Phoenix, Arizona. On July 16, 2024, the Commissioner filed a Motion to Take Deposition Pursuant to Rule 74(c)(3), seeking to take the deposition of Mitch Langstein. According to the Motion, in addition to being a petitioner in several of these cases, "Mitch Langstein wears several important hats in [these cases]. He is the President, CEO, and CFO of Cellular and self-identified as being responsible for Cellular's risk management. He is also the President and Treasurer of Puttus, with responsibility for approving claims." These cases have been characterized as microcaptive insurance cases in which Cellular is the insured and Puttus is the insurer. According to the Commissioner's Motion, the petitioners' have not consented to the deposition. The Motion also implies that petitioners have not refused to have Mr. Langstein sit for a deposition. We will give petitioners an opportunity to respond to the Commissioner's Motion to make their position clear. Accordingly, it is
ORDERED that by July 25, 2024, petitioners shall file a response to the Commissioner's Motion to Take Deposition Pursuant to Rule 74(c)(3).