Opinion
14767-22W
08-19-2022
DENIS M. FRANKENBERGER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On July 1, 2022, petitioner filed the petition to commence this case, indicating that he seeks review of a notice of determination under section 7623 concerning whistleblower action. However, petitioner did not attach to the petition any such notice of determination.
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." Petitioner did not provide a reference list identifying the third-party taxpayer to whom petitioner's claim in this case relates (target taxpayer).
Upon due consideration, it is
ORDERED that, on or before September 12, 2022, petitioner shall file a Response to this Order, designated to be filed "under seal", and therein set forth the name of the target taxpayer in this case. Petitioner additionally shall attach to petitioner's response a copy of the notice of determination concerning whistleblower action upon which this case is based. Petitioner is advised that documents to be filed under seal should be filed in paper form, rather than filed electronically.