Joseph Alan Piole - Page 26




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          Willie Nelson Music Co. v. Commissioner, supra at 918-919, and              
          cases cited therein.                                                        
          In resolving whether a permanent protective order sealing a                 
          portion of the evidentiary record is warranted in this case, we             
          must weigh the public's interest in free and open access to Tax             
          Court proceedings against petitioner's individual interests.                
          Nixon v. Warner Communications, Inc., supra at 602.  The public's           
          interest in open judicial proceedings is presumed to be paramount           
          to the interests of an individual seeking to close the                      
          proceedings in that open proceedings allow the public an                    
          opportunity to understand the underlying dispute and its                    
          disposition, thereby enhancing public confidence in our system of           
          taxation.  Willie Nelson Music Co. v. Commissioner, supra at 919.           
          As previously discussed, petitioner failed to identify the                  
          particular documents or information that he contends should not             
          be disclosed to the public.  Under the circumstances, we conclude           
          that the Court's earlier protective order sealing the record in             
          this case has served its purpose and that the public's interest             
          in open proceedings outweighs any continuing individual interests           
          at stake herein.  Accordingly, we will vacate the protective                
          order dated May 22, 2000.                                                   











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