Keating v. Comm'r of Internal Revenue

Full title: TERENCE J. KEATING & JANET D. KEATING, ET AL., Petitioner v. COMMISSIONER…

Court: United States Tax Court

Date published: Mar 23, 2022

No. 15066-18 (U.S.T.C. Mar. 23, 2022)

Opinion

15066-18 15067-18 15068-18

03-23-2022

TERENCE J. KEATING & JANET D. KEATING, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

L. Paige Marvel, Judge.

ORDER

L. Paige Marvel, Judge.

These consolidated cases were called from the calendar for trial at the Court's San Diego, California, remote trial session on November 1, 2021. Due to an inadvertent clerical error, only two of nine pages of the Court's minutes were placed on the docket causing an incomplete minutes from trial docket entry.

These cases were called from the calendar for further trial on March 14, 2022. On March 15, 2022, counsel for petitioners orally moved to seal exhibit 421-P described in the second stipulation of facts. Upon due consideration and for cause more fully appearing in the transcript of the proceeding, it is

ORDERED that the Court's minutes of these consolidated cases for the November 1, 2021, San Diego, California, remote trial session are hereby stricken from the record and shall not be viewable as part of these cases. It is further

ORDERED that petitioners' oral motion to seal exhibit 421-P is granted in that this exhibit is hereby sealed, to be opened only for good cause shown, until further direction by the Court. It is further

ORDERED that the parties are directed to use any copies of the sealed exhibit 421-P only for the limited purpose of preparing their case before this Court. The parties and their counsel are hereby directed to treat said document in such a manner consonant with its being placed under seal. Counsel for respondent and counsel for petitioners in these cases shall limit access to the material under seal to themselves. The parties and their counsel are directed to make no copies of the sealed exhibit.

Petitioners are advised that pursuant to Rule 143(d)(2) of the Court's Rules of Practice and Procedure, the petitioners may, within 90 days after the decision in these cases become final, make written application to the Clerk of the Court requesting a return of the sealed exhibit, and suggest a practical manner of delivery.