Sam F. and Ingrid D. Ford - Page 15

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          not disclose grand jury matters to the Internal Revenue Service             
          for use in determining or litigating civil tax liability without            
          a showing of particularized need.  Upon such a showing, however,            
          Government attorneys may obtain a "rule 6(e) order" from the                
          District Court permitting such disclosure.  United States v.                
          Baggot, 463 U.S. 476 (1983); United States v. Sells Engg., Inc.,            
          463 U.S. 418 (1983).                                                        
               We have, in one instance, sanctioned the Commissioner, where           
          some of the Commissioner's employees engaged in "extreme and                
          substantial" breaches of grand jury secrecy, one which was                  
          "intentional and flagrant" and lasted "over a period of many                
          years".  Cohen v. Commissioner, T.C. Memo. 1981-345.  On the                
          other hand we have indicated that we shall not impose such                  
          sanctions when doing so would not serve the interests of justice,           
          such as, for example, when "'only isolated and technical                    
          instances of improper disclosure had occurred.'"  Crop                      
          Associates--1986 v. Commissioner, T.C. Memo. 2000-216 (quoting              
          Ballas v. United States (In re Grand Jury Proceedings), 62 F.3d             
          1175, 1178 (9th Cir. 1995)).                                                
               Rule 6(e) "'is intended only to protect against disclosure             
          of what is said or takes place in the grand jury room * * * it is           
          not the purpose of the Rule to foreclose from all future                    
          revelation to proper authorities the same information or                    
          documents which were presented to the grand jury.'"  United                 

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