Anonymous - Page 2

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                                       OPINION                                        

               KROUPA, Judge:  This matter is before the Court on                     
          petitioner’s motion to seal court records.  Petitioner requests             
          us to seal the record in this case and permit petitioner to                 
          proceed anonymously.  Petitioner has demonstrated a significant             
          risk of physical harm to petitioner and petitioner’s family                 
          members if the record were to remain open.  We conclude that it             
          is appropriate to seal the record and permit petitioner to                  
          proceed anonymously.                                                        
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      
                                     Background                                       
               Petitioner is a foreign national.  At the time petitioner              
          filed the petition, petitioner resided outside the United States.           
          A member of petitioner’s family was kidnapped and held for ransom           
          several years ago.  Kidnappings are a rampant problem in the                
          country where petitioner and most of petitioner’s family reside.            
          Petitioner fears that petitioner or other members of petitioner’s           
          family might also be kidnapped and their lives placed in jeopardy           
          if petitioner’s identity or petitioner’s financial circumstances            
          were made public in this case.  Petitioner filed the motion to              
          seal court records at the same time petitioner filed the                    
          petition.                                                                   







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