Opinion
11587-20
10-05-2021
Sirius Solutions, L.L.L.P., Sirius Solutions GP, L.L.C., Tax Matters Partner Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Patrick J. Urda Judge
On August 26, 2021, petitioner, Sirius Solutions, L.L.L.P., filed a motion to seal seeking to seal certain 2014 tax returns, which had been attached as exhibits to the Commissioner's response to Sirius' motion for summary judgment. (Doc. 23 at 2.) On September 13, 2021, the Commissioner filed a response in opposition. (Doc. 26.)
In support of its motion, Sirius argues that the returns contain personal and financial information about the limited partners. (Doc. 23 at 4.) In particular, Sirius contends that disclosure of this information presents serious privacy and security concerns and has the potential to do irreparable harm, particularly to the partners' minor children. (Doc. 23 at 4.)
For his part, the Commissioner argues that Sirius has failed to demonstrate any specific cause for protection. He notes that the return information dates from 2014, which suggests that the information contained therein may no longer be sensitive. He also points out that the temporal interval may lessen concerns about children, some of whom (apparently) have achieved majority. (Doc 26 at 7, 9.) And he contends that similar privacy concerns to the ones raised by Sirius are present in nearly every case before this Court.
It would be helpful for the Court to hear from Sirius on these points, bearing in mind that the party seeking to seal the case must produce "appropriate testimony and factual data" to support claims of harm that would occur as a consequence of disclosure, Estate of Yaeger v. Commissioner, 92 T.C. 180, 189 (1989), and may not rely on conclusory or unsupported statements to establish good cause, Willie Nelson Music Co. v. Commissioner, 85 T.C. 914, 920 (1985). Accordingly, it is
ORDERED that petitioner shall file a reply to respondent's response to petitioner's motion to seal no later than October 25, 2021.
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