Thomas J. and Bonnie F. Ratke - Page 1
129 T.C. No. 6
UNITED STATES TAX COURT
THOMAS J. AND BONNIE F. RATKE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 9641-01L. Filed September 5, 2007.
After this Court ruled for Ps in the instant
collection case, Ps moved for an award of costs under
sec. 7430, I.R.C. 1986, and then for sanctions under
sec. 6673(a)(2), I.R.C. 1986. In connection with these
motions, Ps seek discovery of (1) a memorandum sent by
R’s initial trial counsel to R’s national office at the
time R’s answer was filed in the instant case and (2)
the unredacted version of the responding memorandum
sent a few months later by R’s national office. R
provided to Ps a redacted version of the latter
memorandum. R resists discovery of the unredacted
memoranda, claiming work product doctrine privilege.
*This opinion supplements Ratke v. Commissioner, T.C. Memo.
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Last modified: November 10, 2007