Opinion
1434-23W
08-28-2023
ORDER
Kathleen Kerrigan Chief Judge
On August 28, 2023, respondent filed (1) a Motion for Summary Judgment, (2) a Declaration of Debra B. McCullum in Support of Motion for Summary Judgment, and (3) a Motion to Seal. In his Motion to Seal, respondent requests that the just-described Declaration and its attachments be sealed as "[d]ue to the frequency of the identifying information [of petitioner and the target taxpayer] in the [documents attached to the declaration], the redaction of all such information would be impractical and make these documents unintelligible to the Court, even were a reference list created for those documents." Petitioner does not seek in this case to proceed anonymously, however, pursuant to Rule 345(b), Tax Court Rules of Practice and Procedure, the Court generally strives to keep the identity of the third-party target taxpayer confidential.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Seal is granted and the Declaration of Debra B. McCullum in Support of Motion for Summary Judgment is sealed from public view and shall not be inspected by any person or entity not a party to this case, except by an Order of the Court.