Opinion
15374-20W
01-26-2022
Rimon Abdou Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On September 14, 2020, petitioner filed the petition to commence this case pursuant to Internal Revenue Code section 7623. The Court's $60.00 filing fee for this case was not paid.
Petitioner also did not submit with the petition a Request for Place of Trial. The Court, therefore, will designate the place of trial in this case. If petitioner wishes to designate a place of trial other than the place of trial designated by the Court below, petitioner may file a Motion To Change Place of Trial, designating a place of trial at which the Court tries regular tax cases (any city not marked with an asterisk on the Request for Place of Trial form, which is available on the Court's website, www.ustaxcourt.gov, by clicking on "eFiling & Case Maintenance", then clicking on "Case Related Forms").
The parties are reminded that, under Rule 345(b), Tax Court Rules of Practice and Procedure, when filing documents in a whistleblower action, the party making the filing "shall refrain from including, or shall take appropriate steps to redact, the name, address, and other identifying information of the taxpayer to whom the claim relates." Rule 345(b) further provides that the party "filing a document that contains redacted information shall file under seal a reference list that identifies each item of redacted information and specifies an appropriate identifier that uniquely corresponds to each item listed."
Upon due consideration, it is
ORDERED that, pursuant to Rule 345(b), in future filings of documents that are not filed under seal, the parties shall take appropriate steps to redact the name, address, and other identifying information of the taxpayer(s) to whom the claims in this case relate (the target taxpayers) and, when appropriate, either (1) concurrently file or lodge under seal a reference list that identifies each item of redacted information and specifies an appropriate identifier that uniquely corresponds to each item listed or (2) concurrently file or lodge under seal an unredacted version of any redacted document that is filed or lodged. Documents to be filed under seal must be submitted to the Court in paper form.
If utilizing the first method, the parties shall file or lodge redacted versions of documents accompanied by a reference list of redacted information, which must be filed or lodged under seal and specifically identify and state each item of redacted information (for example, when the target taxpayer's name is redacted, the reference list must identify that redaction and also state the target taxpayer's name). Subsequent references in the case to a listed identifier will be construed to refer to the corresponding item of information.
If utilizing the second method, the versions shall be clearly marked as "Unredacted" or "Redacted", as appropriate, and the redacted version shall be an exact duplicate of the corresponding unredacted version, including attachments and exhibits, except for the redactions made with respect to the identifying information of the target taxpayer. It is further
ORDERED that, on or before February 16, 2022, petitioner shall file a Response to this Order. That response shall be marked "File Under Seal" and therein petitioner shall set forth the names of the target taxpayers in this case. It is further
ORDERED that, on or before February 16, 2022, petitioner shall pay the Court's $60.00 filing fee for this case. Instructions on how to pay the filing fee can be found in the "Guidance for Petitioners" tab of the Court's website at www.ustaxcourt.gov.
ORDERED that Nashville, Tennessee is designated as the place of trial.
The Court encourages all litigants to register for electronic access (eAccess) so that they may electronically file and view documents in their Tax Court cases. If you currently file in paper and/or receive paper service from the Court, you are encouraged to register for eAccess by emailing dawson.support@ustaxcourt.gov. If you did not electronically file the petition to commence your case and you have not previously registered for eAccess, please do not attempt to electronically file documents in your case without first contacting dawson.support@ustaxcourt.gov to register for eAccess.