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Amgen Inc. v. Comm'r of Internal Revenue

United States Tax Court
Jul 26, 2024
No. 16017-21 (U.S.T.C. Jul. 26, 2024)

Opinion

16017-21 15631-22

07-26-2024

AMGEN INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Travis A. Greaves Judge.

These consolidated cases are before the Court on petitioner's Motion to Unseal HCR Fee Pleadings, filed June 10, 2024, and petitioner's Motion to Unseal Due Process Pleadings, filed June 10, 2024. Therein, petitioner requests that we seal specific portions of the pleadings discussed in the motions. Petitioner improperly filed versions of these pleadings with unagreed redactions. These documents will be stricken, and the Court will order petitioner to file properly redacted documents after ruling on these motions.

There is a strong presumption of public access to court records. Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 1122, 1135 (9th Cir. 2003). A party seeking to seal judicial records, including exhibits attached to dispositive motions, bears the burden of overcoming this strong presumption by showing a compelling reason for sealing such records. Id. at 1136. Petitioner has failed to set forth a specific list of the requested redactions and the justification for each redaction.

Upon due consideration, it is

ORDERED that the Declaration of Jenny Chang in Support of Petitioner's Motion for Summary Judgment on HCR Fees Penalties, filed June 10, 2024, is hereby deemed stricken from the Court's record in these cases. It is further

ORDERED that respondent's Opposition to Petitioner's Motion for Partial Summary Judgment on HCR Fees, filed June 10, 2024, is hereby deemed stricken from the Court's record in these cases. It is further

ORDERED that the Declaration of Gregory A. Spring, filed June 10, 2024, is hereby deemed stricken from the Court's record in these cases. It is further

ORDERED that respondent's Opposition to Petitioner's Motion for Partial Summary Judgment on HCR Fees Penalties, filed June 10, 2024, is hereby deemed stricken from the Court's record in these cases. It is further

ORDERED that the Unsworn Declaration of Shannon L. Cohen, filed June 10, 2024, is hereby deemed stricken from the Court's record in these cases. It is further

ORDERED that the Declaration of Jenny Chang in Support of Petitioner's Motion for Partial Summary Judgment on HCR Fees, filed June 10, 2024, is hereby deemed stricken from the Court's record in these cases. It is further

ORDERED that respondent's Motion for Partial Summary Judgment (Petitioner's Due Process Claim), filed June 10, 2024, is hereby deemed stricken from the Court's record in these cases. It is further

ORDERED that the Declaration of Megan Heinz, filed June 10, 2024, is hereby deemed stricken from the Court's record in these cases. It is further

ORDERED that respondent's Reply to Petitioner's Opposition to Respondent's Motion for Partial Summary Judgment on Petitioner's Due Process Claim, filed June 10, 2024, is hereby deemed stricken from the Court's record in these cases. It is further

ORDERED that respondent's Response to Petitioner's Motion for Leave to File First Amendment to Petition, filed June 10, 2024, is hereby deemed stricken from the Court's record in these cases. It is further

ORDERED that petitioner's Opposition to Respondent's Motion for Partial Summary Judgment (Petitioner's Due Process Claim), filed June 10, 2024, is hereby deemed stricken from the Court's record in these cases. It is further

ORDERED that the Declaration of Jenny Chang in Support of Petitioner's Opposition to Respondent's Motion for Partial Summary Judgment, filed June 10, 2024, is hereby deemed stricken from the Court's record in these cases. It is further

ORDERED that, on or before August 26, 2024, petitioner shall file a supplement to its Motion to Unseal HCR Fee Pleadings, filed June 10, 2024, setting forth a list of requested redactions with corresponding justifications. It is further

ORDERED that, on or before August 26, 2024, petitioner shall file a supplement to its Motion to Unseal Due Process Pleadings, filed June 10, 2024, setting forth a list of requested redactions with corresponding justifications.


Summaries of

Amgen Inc. v. Comm'r of Internal Revenue

United States Tax Court
Jul 26, 2024
No. 16017-21 (U.S.T.C. Jul. 26, 2024)
Case details for

Amgen Inc. v. Comm'r of Internal Revenue

Case Details

Full title:AMGEN INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Jul 26, 2024

Citations

No. 16017-21 (U.S.T.C. Jul. 26, 2024)