Jeffrey T. Piampiano, Ch. 7 Trustee of the Estate of Sky-Skan Inc. v. Stuart B. Ratner and Stuart B. Ratner, P.C.

2023 DNH 139
CourtDistrict Court, D. New Hampshire
DecidedNovember 6, 2023
Docket22-cv-003-SE
StatusPublished
Cited by1 cases

This text of 2023 DNH 139 (Jeffrey T. Piampiano, Ch. 7 Trustee of the Estate of Sky-Skan Inc. v. Stuart B. Ratner and Stuart B. Ratner, P.C.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jeffrey T. Piampiano, Ch. 7 Trustee of the Estate of Sky-Skan Inc. v. Stuart B. Ratner and Stuart B. Ratner, P.C., 2023 DNH 139 (D.N.H. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Jeffrey T. Piampiano, Ch. 7 Trustee of the Estate of Sky-Skan Inc.

v. Case No. 22-cv-003-SE Opinion No. 2023 DNH 139 Stuart B. Ratner and Stuart B. Ratner, P.C.

ORDER

New Hampshire Rev. Stat. Ann. (“RSA”) § 508:4 includes a

“discovery rule” that tolls the three-year statute of

limitations for personal actions when the plaintiff could not

reasonably have discovered his injury or its causal relationship

to the acts or omissions that led to his injury. The discovery

rule does not, however, allow an otherwise time-barred action

when the plaintiff ignored his potential injury and made no

reasonable effort to discover the acts or omissions that led to

it.

In this case, the Chapter 7 Trustee for Sky-Skan Inc.,

Jeffrey T. Piampiano (the “Trustee”), brings malpractice and

breach of fiduciary duty claims against Sky-Skan’s former

lawyer, Stuart Ratner and Stuart Ratner, P.C. (collectively,

“Ratner”).1 The claims arise out of Ratner’s alleged failure in

1The Trustee alleges that Ratner was Sky-Skan’s attorney at all relevant times. Ratner does not dispute this fact for the purpose of summary judgment. Doc. no. 11-1, ¶ 19. October and November 2017 to inform Sky-Skan that the Internal

Revenue Service had granted a crucial extension related to its

federal tax debts. Sky-Skan’s mistaken belief that the IRS had

not granted the extension allegedly caused it to file for

bankruptcy and suffer harm.

Because Ratner’s actions and Sky-Skan’s bankruptcy filing

occurred more than three years before the Trustee asserted the

claims in this suit, those claims are barred by RSA § 508:4

unless the statute of limitations is tolled. The Trustee argues

that the discovery rule applies because Sky-Skan reasonably

expected Ratner to notify it if the IRS granted the extension,

which would have prevented bankruptcy.

That argument misunderstands the discovery rule. Even if

Sky-Skan reasonably assumed that Ratner would convey any updates

regarding the extension, that does not save the Trustee’s claims

from the statute of limitations. Rather, the discovery rule

applies only if Sky-Skan could not have reasonably discovered

the extension. As discussed further below, there is no

allegation or evidence to support that contention. Therefore,

the discovery rule does not apply. For this reason, and because

the Trustee’s argument regarding fraudulent concealment is

unavailing, the Trustee’s claims are time-barred, and the court

grants Ratner’s motion for summary judgment (doc. no. 11).

2 Standard of Review

Granting summary judgment is appropriate “if the movant

shows that there is no genuine dispute as to any material fact

and the movant is entitled to judgment as a matter of law.” Fed.

R. Civ. P. 56(a). A material fact is one that “carries with it

the potential to affect the outcome of the suit.” French v.

Merrill, 15 F.4th 116, 123 (1st Cir. 2021) (quotation omitted).

A material fact is in genuine dispute if “a reasonable jury

could resolve the point in the favor of the non-moving party.”

Id. In considering a motion for summary judgment, the court may

review materials cited in the motion and other materials in the

record. Fed. R. Civ. P. 56(c)(1)(3).

Background

Steven and Virginia Savage owned and operated Sky-Skan,

which “was in the business of systems integration for theater

systems and planetariums.” Doc. no. 15-1, ¶ 1. To fund the

business, Sky-Skan had taken out loans worth $1,040,000 from

Bank of America, N.A. Those loans were later sold to Coastal

Capital, LLC (“Coastal”), who acquired distressed assets.

In the months following Coastal’s purchase of the Sky-Skan

debt, the parties corresponded regarding the potential terms on

which Sky-Skan would repay Coastal. Sky-Skan was experiencing

financial difficulties and could not immediately pay Coastal

3 what it owed. On August 17, 2017, Coastal filed an action

against Sky-Skan in New Hampshire state court seeking to attach

its assets because Richard Gleicher, Coastal’s member-manager,

had lost faith in the Savages. On September 22, 2017, the state

court issued an order granting Coastal’s attachment.

In addition to its loan debt, Sky-Skan owed the IRS

$751,428. Prior to Coastal’s state court action, Sky-Skan had

retained an IRS-credentialed agent to help resolve its unpaid

federal tax liability. That agent negotiated an offer-in-

compromise (“OIC”) with the IRS that would have allowed Sky-Skan

to resolve its tax liability for $185,618. The deadline for Sky-

Skan to agree to the OIC was October 23 or 24, 2017.2 A condition

of the OIC was that Sky-Skan would immediately pay a deposit

equal to 20 percent of the total compromised amount.

Given the state court order attaching Sky-Skan’s assets,

the Savages sought approval from Coastal to pay the deposit to

the IRS pursuant to the OIC. Coastal was not willing to approve

that payment without additional information. Consequently, Sky-

Skan did not accept the IRS’s offer prior to the October 23 or

24 deadline. However, Coastal notified Sky-Skan that it was

retaining a tax expert, Ratner, to help it better understand the

2 The parties agree that the OIC deadline was either October 23 or 24, 2017. See doc. no. 11-1, ¶ 54; doc. no. 15-1, ¶ 4.

4 merits of the OIC and for the express purpose of seeking an

extension of the already-expired IRS deadline to fund the OIC.

In order to facilitate Ratner’s efforts, on October 27,

2017, Virginia Savage signed an IRS “Power of Attorney and

Declaration of Representative” form, which gave Ratner power of

attorney for Sky-Skan before the IRS.3 Ratner also spoke with Ms.

Savage and informed her that he would seek a 30-day extension

from the IRS for the parties to consider the OIC further. She

testified in her deposition as follows:

Q: Did Mr. Ratner indicate to you a possibility of getting an extension relative to the offer in compromise addendum?

A: He mentioned that, but at that point we were already past the deadline . . . for the offer in compromise.”

. . . .

Q: [W]as it your understanding that among the things he was going to request from the IRS would be a further extension of that already lapsed deadline under the offer in compromise addendum?

A: Yes, I believe so.

Doc. no. 11-2 at 9-10.

On that same day, October 27, 2017, Ratner spoke with the

IRS agent who was handling the Sky-Skan OIC. That agent told

Ratner that the IRS would grant the requested extension through

3 The form gave both Stuart Ratner and his associate, Laura Rodriguez, power of attorney. See doc. no. 15-15.

5 November 30, 2017.4 Ratner did not notify the Savages or anyone

else at Sky-Skan that the IRS had granted the extension, either

on October 27 or at any time thereafter. No one from Sky-Skan,

including its bankruptcy attorney, inquired with Ratner or the

IRS regarding the status of the extension.

On November 1, 2017, having not heard from Ratner and

assuming he would have reached out had his efforts with the IRS

been successful, Sky-Skan filed for bankruptcy. According to its

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Related

Piampiano v. Ratner
D. New Hampshire, 2023

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2023 DNH 139, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeffrey-t-piampiano-ch-7-trustee-of-the-estate-of-sky-skan-inc-v-nhd-2023.