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Royalty Mgmt. Ins. Co. v. Comm'r of Internal Revenue

United States Tax Court
Nov 2, 2022
No. 3823-19 (U.S.T.C. Nov. 2, 2022)

Opinion

3823-19 4421-19

11-02-2022

ROYALTY MANAGEMENT INSURANCE COMPANY, LTD., ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

ALBERT G. LAUBER JUDGE

These "micro-captive" insurance cases involving petitioners' 2012 tax year are calendared for trial at a two-week special session in Oklahoma City, Oklahoma, beginning February 13, 2023. On October 31, 2022, petitioners filed, pursuant to Tax Court Rules 74(c)(3) and 81(c), an Application to Take Deposition of Aisha Sims, a revenue agent employed by the Internal Revenue Service (IRS or respondent). Ms. Sims was involved in the examination of petitioners' 2012 tax year. Petitioners represent that they provided Ms. Sims with certain documents relevant to the insurance transactions and that, at some point during the examination, these documents "were lost and never returned to petitioners." Petitioners contend that Ms. Sims may have knowledge about the allegedly lost documents and also seek to depose her about other aspects of the IRS examination.

Upon due consideration, it is

ORDERED that respondent shall file, on or before November 23, 2022, a response to petitioner's Application to Take Deposition of Aisha Sims. In his response, respondent shall indicate whether he would object to a deposition limited in scope to the allegedly lost documents.


Summaries of

Royalty Mgmt. Ins. Co. v. Comm'r of Internal Revenue

United States Tax Court
Nov 2, 2022
No. 3823-19 (U.S.T.C. Nov. 2, 2022)
Case details for

Royalty Mgmt. Ins. Co. v. Comm'r of Internal Revenue

Case Details

Full title:ROYALTY MANAGEMENT INSURANCE COMPANY, LTD., ET AL., Petitioners v…

Court:United States Tax Court

Date published: Nov 2, 2022

Citations

No. 3823-19 (U.S.T.C. Nov. 2, 2022)