Melea Limited v. Commissioner

118 T.C. 218 (2002)

From our private database of 46,000+ case briefs, written and edited by humans—never with AI.

Melea Limited v. Commissioner

United States Tax Court
118 T.C. 218 (2002)

Facts

Michael Ladney was the principal shareholder in several United States corporations. Switzerland-based Melea Limited (plaintiff) was incorporated in Gibraltar. Melea was a defendant (along with an unrelated company) in a federal patent-infringement suit in Florida in which depositions were taken to determine Melea’s relationship with two of Ladney’s corporations. Discovery in the Florida case was governed by a stipulated protective order that the Florida court approved. The protective order provided that (1) a party could designate documents as confidential, (2) documents classified as confidential could be disclosed only in the Florida litigation absent approval of the Florida court, and (3) the order survived the termination of the Florida litigation. The Florida suit was terminated in 1998. Melea also was embroiled in a dispute with the Internal Revenue Service (IRS) regarding the relationship between Melea and the two Ladney companies concerned in the Florida litigation. Melea filed a petition with the United States Tax Court against the IRS commissioner (defendant). In response to the commissioner’s request, Melea produced redacted copies of deposition transcripts from the Florida litigation relating to the relationship between Melea and the Ladney entities. The redactions reflected material that was classified as confidential. The commissioner moved to compel Melea to produce the redacted material, arguing that the Tax Court should compel its production because (1) the protective order reflected the Florida court’s approval of the parties’ agreement rather than its deliberate resolution of a controversy, (2) Melea originally was entitled to the relevant transcripts, (3) seeking relief from the Florida court would be burdensome and expensive and would inconvenience the Florida court, and (4) the Tax Court could continue the protective order’s protections. Melea responded that (1) the protective order was the product of the Florida court’s hearings and intervention to resolve the parties’ divergent positions and thus the court did more than just approve the parties’ agreement; (2) any of the Florida litigants could have designated the material as confidential (although there was no evidence that the redacted material exclusively came from another party); (3) notwithstanding the conceded burden and expense, the commissioner had to ask the Florida court for the redacted material; and (4) any Tax Court order had to protect proprietary business information.

Rule of Law

Issue

Holding and Reasoning (Gerber, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 742,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 742,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,000 briefs, keyed to 986 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 742,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,000 briefs - keyed to 986 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership