Opinion
19210-21W
09-28-2021
Ronald R. Kopko Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On August 18, 2021, petitioner filed the petition to commence this whistleblower case pursuant to Internal Revenue Code section 7623, seeking review of a notice of determination under section 7623 concerning whistleblower action, dated July 19, 2021. Petitioner does not indicate the identity of the taxpayer to whom the whistleblower claim relates (target taxpayer).
The parties are reminded that unless a document is filed under seal, under Rule 345(b), Tax Court Rules of Practice and Procedure, in an unsealed filing with the Court 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 and for cause, it is
ORDERED that, when filing or lodging unsealed documents in this case, the parties shall refrain from including, or take appropriate steps to redact the name, address, and other identifying information of the target taxpayer 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 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 October 18, 2021, petitioner shall file under seal a Response to this Order setting forth the name(s) of the target taxpayer(s) in this case.