Opinion
12214-20
05-23-2023
TOSCANO HOLDINGS, LLC, TOSCANO INVESTMENTS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris Judge
The Court received a copy request from a non-party to this proceeding for several documents. After review, we note that the petitioner has failed to fully redact a filing in one instance.
Rule 27(a) of the Tax Court Rules of Practice and Procedure provides that a party or non-party shall refrain from including or shall take appropriate steps to redact the following information in any paper or electronic filing with the Court:
(1) Taxpayer identification numbers (e.g., Social Security numbers or employer identification numbers).
(2) Dates of birth. If a date of birth is provided, only the year should appear.
(3) Names of minor children. If a minor child is identified, only the minor child's initials should appear.
(4) Financial account numbers. If a financial account number is provided, only the last four digits of the number should appear.
Rule 27(h) further provides that a party may correct an inadvertent disclosure of identifying information in a prior filing by submitting a properly redacted substitute by leave of Court.
As a court of public record, non-parties can request copies, but the Court will give the parties 14 days to review the identified document(s) below, correct any omission of redactions pursuant to Rule 27(a), and request leave to file properly redacted substitute documents.
It is therefore, ORDERED that petitioner's: "Declaration of Michelle Levin in Support of Motion to Invalidate the Final Partnership Administrative Adjustment and Incorporated Memorandum of Law," filed electronically on April 25, 2023, docket entry 33, is placed under temporary seal and shall remain under seal until further direction of the Court.