Wilson v. Comm'r of Internal Revenue

Full title: DAVID ALLEN WILSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court: United States Tax Court

Date published: Aug 19, 2022

No. 5512-20W (U.S.T.C. Aug. 19, 2022)

Opinion

5512-20W

08-19-2022

DAVID ALLEN WILSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

David Gustafson Judge

ORDER

David Gustafson Judge

This is a "whistleblower" case brought under section 7623. By this order we will direct that the general seal on the record of this case be lifted and will give instructions as to the continuing seal on individual documents.

Sealed filings in this case

Pursuant to our previous order certain documents filed in this case were sealed (Doc. 1) or were stricken and sealed (Docs. 10-33). We ordered them to be filed under seal in order to protect from disclosure certain confidential information about third parties. (See Docs. 5, 34.)

Since then, similar information has been included in other filings (Doc. 51, 53-58, 80), some of which were stricken (see Doc. 62) but not yet sealed. We will now order that those documents will be sealed.

Sealing of cases vs. documents

In late 2020 the Court commenced filing under the "minimum viable product" of its new "DAWSON" e-filing system; and thereafter, under that provisional regime, the filing of individually sealed documents was not possible. Consequently, while the Court operated under that provisional version, the electronic docket of a case was completely sealed if that case had any sealed document in its record. It was intended that the general sealing remain in place until the Court was able to install in DAWSON the function of sealing an individual document.

It is now possible to seal individual documents and to otherwise unseal the case in which they were filed. It is therefore

ORDERED that the Clerk of the Court shall place under seal Docs. 51, 53-58, and 80, and that the Clerk of the Court shall remove the documents from the Court's public records, and that the documents shall be retained by the Court in a sealed file which shall not be inspected by any person or entity not a party, except by an order of the Court. It is further

ORDERED that the Clerk of the Court shall lift the general seal on the record of this case, and that hereafter only those individual documents that the Court has ordered to be sealed (i.e., Docs. 1, 10-33, 51, 53-58, and 80) shall remain under seal.