- 15 - that counsel can stipulate as to which facts were set forth and which facts were not set forth (omitted) in Ms. Welhaf’s Memorandum to the Chief Counsel’s Office.” Respondent contends: 8. As far as Ms. Welhaf’s opinion work product is concerned, it is respondent’s view that such opinion work product is absolutely protected from disclosure. We reject both sides’ contentions insofar as they would preclude us from conducting an appropriate balancing of interests in section 7430 and section 6673(a)(2) disputes. We decline to adopt either side’s approach. In an effort to give meaningful effect to the relevant public policies in a practical way in the instant case, we chose to conduct in camera inspections of the two unredacted memoranda. We recognize that other courses of action may be preferable in other circumstances. 4. Application to This Case Having conducted an in camera review of the Welhaf memorandum and the unredacted Hyman memorandum, we conclude there is neither a substantial need to discover any of the fact-based work product nor compelling need to discover any of the opinion work product. A redacted version of the Hyman memorandum was provided to petitioners. The redacted version of the Hyman memorandum discloses the statements about matters of fact, but not all of the legal strategies or opinions, set forth in the unredactedPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: November 10, 2007