Patel v. Comm'r of Internal Revenue

Full title: SUNIL S. PATEL & LAURIE MCANALLY PATEL, ET. AL., Petitioners v…

Court: United States Tax Court

Date published: Mar 22, 2022

No. 24344-17 (U.S.T.C. Mar. 22, 2022)

Opinion

24344-17 11352-18 25268-18

03-22-2022

SUNIL S. PATEL & LAURIE MCANALLY PATEL, ET. AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Courtney D. Jones Judge

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 24, 2022, petitioners filed motions to compel the taking of depositions of respondent's expert witnesses Roberta J. Garland, David T. Russell, and Akos Swierkiewicz.

On March 4, 2022, respondent filed objections to petitioners' motions as to each of the three experts. On March 7, 2022, petitioners filed replies to respondent's objections. The same day, respondent filed motions for leave to file sur-replies to reply and lodged the sur-replies therewith.

Upon due consideration, it is

ORDERED that respondent's motion for leave to file sur-reply to reply to respondent's objection to petitioners' motion to compel the taking of deposition of Roberta J. Garland, filed March 7, 2022, is granted and the sur-reply is filed as of the date of lodging. It is further

ORDERED that respondent's motion for leave to file sur-reply to reply to respondent's objection to petitioners' motion to compel the taking of deposition of David T. Russell, filed March 7, 2022, is granted and the sur-reply is filed as of the date of lodging. It is further

ORDERED that respondent's motion for leave to file sur-reply to reply to respondent's objection to petitioners' motion to compel the taking of deposition of Akos Swierkiewicz, filed March 7, 2022, is granted and the sur-reply is filed as of the date of lodging. For the reasons set forth in respondent's submissions, it is further

ORDERED that petitioners' motion to compel the taking of deposition of Roberta J. Garland, filed February 24, 2022, is denied. It is further

ORDERED that, petitioners' motion to compel the taking of deposition of David T. Russell, filed February 24, 2022, is denied. It is further

ORDERED that petitioners' motion to compel the taking of deposition of Akos Swierkiewicz, filed February 24, 2022, is denied.