Court of Appeals for the D.C. Circuit October 27, 1995, 94-5280 (The Penn Mutual Life Insurance Company v. United States of America and the Internal Revenue Service)

Opinion for the Court filed by Circuit Judge WALD.

WALD, Circuit Judge:

Appellants Penn Mutual Life Insurance Company, Provident Mutual Life Insurance Company, and State Mutual Life Assurance Company of America (“appellants”) seek reversal of the district court’s denial of their motion to perpetuate testimony by taking depositions pursuant to Rule 27(a) of the Federal Rules of Civil Procedure