118 T.C. No. 35
UNITED STATES TAX COURT
JEFFREY HAMBARIAN AND VIRGINIA M. HAMBARIAN, ET AL.,1
Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 11856-99, 7973-00, Filed June 13, 2002.
3042-01, 3101-01.
P is a defendant in a criminal proceeding. The
transactions and circumstances which gave rise to the
criminal proceeding were also the predicate for R’s
civil tax determination. P’s criminal defense attorney
selected 100,000 pages of documents from a much larger
universe of documents that were in the possession of
the prosecuting attorney. The documents were converted
by P’s defense attorney into computer searchable media.
R seeks the production of copies of the documents and
computer searchable media. P resists turning over the
documents or media on the grounds that his defense
1 Cases of the following petitioners are consolidated
herewith: Jeffrey Hambarian and Virginia M. Hambarian, docket
No. 7973-00, Virginia M. Hambarian, docket No. 3042-01, and
Jeffrey A. Hambarian, docket No. 3101-01.
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