Anonymous - Page 7

                                         -7-                                          
          names to be included on pleadings and other papers filed with the           
          Court.  See Rules 32(a) (requiring a party’s name to be set forth           
          on pleadings), 23(a) (requiring all papers filed to contain the             
          full name and surname of each petitioner), 60(a) (requiring a               
          case be brought by and in the name of a person against whom the             
          Commissioner determined the deficiency in the case of a                     
          deficiency notice).                                                         
               When there is no applicable Rule, we may prescribe the                 
          procedure, giving particular weight to the Federal Rules of Civil           
          Procedure to the extent adaptable to the matter at hand.  Rule              
          1(a).  Where our Rules are silent, we have looked to the Federal            
          Rules of Civil Procedure and cases in other Federal courts                  
          interpreting the Federal Rules of Civil Procedure for guidance.             
          See Willie Nelson Music Co. v. Commissioner, 85 T.C. at 917                 
          (looking to decisions interpreting rule 26(c) of the Federal                
          Rules of Civil Procedure for guidance in interpreting Rule                  
          103(a)); Allen v. Commissioner, 71 T.C. 577, 579 (1979).                    
               Several U.S. Courts of Appeals have permitted litigation to            
          proceed anonymously.  See, e.g., Does I Thru XXIII v. Advanced              
          Textile Corp., supra at 1067; James v. Jacobson, 6 F.3d 233, 238            
          (4th Cir. 1993); Doe v. Stegall, 653 F.2d 180, 185-186 (5th Cir.            
          1981).  The Supreme Court and the U.S. Court of Appeals for the             
          District of Columbia Circuit have occasionally permitted                    


               1(...continued)                                                        
          identifying information.  Sec. 6110(a), (c).  A person may act to           
          restrain disclosure of these materials, however, under the                  
          procedures set forth in sec. 6110(f).                                       




Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011