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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).
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