Herrmann v. United States

Tax case; motion to compel deposition and document production from the government; motion to compel document production from a nonparty; motion by the nonparty for a protective order

OPINION AND ORDER

LETTOW, Judge.

Plaintiffs in this tax case, Jeffrey Herr-mann and Mina Gerowin Herrmann (the “Herrmanns”), seek a refund of income tax and interest paid in connection with receipt by Ms. Herrmann of $18,748,838 in the beginning of 2009 while she was resident in London working for Paulson Europe LLP (“PELLP”). The key question in the case is whether Ms. Herrmann received that payment as a…