Jeffrey and Virginia M. Hambarian - Page 1

          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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