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