Opinion
24344-17 11352-18 25268-18
11-05-2021
Sunil S. Patel & Laurie McAnally Patel, ET AL., Petitioners v. Commissioner of Internal Revenue, Respondent
ORDER
Courtney D. Jones Judge
These cases concern whether certain entities formed by petitioners, Magellan Insurance Company Ltd. (Magellan) and Plymouth Insurance Company, Inc. (Plymouth), were micro-captive insurance companies and engaged in insurance transactions for Federal income tax purposes. See sec. 831(b).
On October 29, 2021, respondent filed a Motion to Compel the Taking of Deposition of Nonparty Witness Bryan Ridgway under Rule 74(c). Petitioners do not appear to dispute that Mr. Ridgway served as an advisor in the formation of their micro-captive arrangement and further served as its administrator. Accordingly, it appears to the Court that Mr. Ridgway's deposition is warranted as it is likely to lead to admissible evidence.
The Court continues to note petitioners' prior resistance to discovery that the Court ultimately found proper. Notwithstanding the aforementioned points, we will permit petitioners an opportunity to formally respond to the present motion prior to ruling on it.
Upon due consideration and for cause, it is
ORDERED that petitioner, on or before November 24, 2021, shall file a response to respondent's Motion to Compel the Taking of Deposition of Nonparty Witness Byran Ridgway.