Opinion
10199-23
01-25-2024
LILI TALEB, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE.
Upon further review of the record in this case, it appearing that petitioner seeks review of a notice of determination concerning whistleblower action, it is
ORDERED that the petition in this case shall be treated as a Petition for Whistleblower Action Under Code Section 7623(b)(4). It is further
ORDERED that the caption of this case is amended by adding the letter "W" to the docket number. It is further
ORDERED that the Clerk of the Court shall add the letter "W" to the docket sheet and other records of that office and process this case to trial or other disposition according to the procedures provided by Rules 340 through 345, Tax Court Rules of Practice and Procedure. It is further
ORDERED that pursuant to Rule 345(b) in the future, when filing or lodging documents in this case that are not sealed, 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) Docket No. 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, 2024, petitioner shall file a Response to this Order and therein identify the third-party taxpayer(s) to whom petitioner's claims in this case relate. In accordance with the instructions above, that Response shall be submitted in paper form and marked "to be filed under seal".