Opinion
24344-17 11352-18 25268-18
03-17-2022
SUNIL S. PATEL & LAURIE MCANALLY PATEL, ET. AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones Judge
This consolidated case is scheduled for trial at a special session of the Court, to commence on April 25, 2022. On February 9, 2022, petitioners filed a motion for partial summary judgment, asking the Court to rule that Magellan Insurance Company, Ltd. and Plymouth Insurance Company, Inc. were adequately capitalized for Federal income tax purposes. On March 3, 2022, respondent filed a response to petitioners' motion.
Upon due consideration, it is
ORDERED that, petitioners' motion for partial summary judgment, filed February 9, 2022, is denied.