Legal Opinion

Hambarian v. Comm'r

United States Tax Court

Decided June 13, 2002No. 11856-99; No. 7973-00; No. 3042-01; No. 3101-01Published

P is a defendant in a criminal proceeding. The transactions and circumstances which gave rise to the criminal proceeding were also the predicate for R's civil tax determination. P's criminal defense attorney selected 100,000 pages of documents from a much larger universe of documents that were in the possession of the prosecuting attorney. The documents were converted by P's defense attorney into computer searchable media.

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P is a defendant in a criminal proceeding. The transactions and circumstances which gave rise to the criminal proceeding were also the predicate for R's civil tax determination. P's criminal defense attorney selected 100,000 pages of documents from a much larger universe of documents that were in the possession of the prosecuting attorney. The documents were converted by P's defense attorney into computer searchable media. R seeks the production of copies of the documents and computer searchable media. P resists turning over the documents or media on the grounds that his defense attorney's…

1Opinion of the Court

JEFFREY HAMBARIAN AND VIRGINIA M. HAMBARIAN, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Hambarian v. Comm'r

No. 11856-99; No. 7973-00; No. 3042-01; No. 3101-01

United States Tax Court

118 T.C. 565; 2002 U.S. Tax Ct. LEXIS 35; 118 T.C. No. 35; T.C.M. (RIA) 54784; 83 T.C.M. (CCH) 4175; 52 Fed. R. Serv. 3d (Callaghan) 1280;

June 13, 2002, Filed

Respondent's motion to compel granted.

P is a defendant in a criminal proceeding. The transactions

and circumstances which gave rise to the criminal proceeding

were also the predicate for R's civil tax determination. P's

criminal defense…

2Cases cited10 opinions

  1. Hickman v. TaylorSupreme Court of the United States · 1947
  2. Sporck v. PeilCourt of Appeals for the Third Circuit · 1985
  3. In Re San Juan Dupont Plaza Hotel Fire Litigation. Petition of the Plaintiffs' Steering CommitteeCourt of Appeals for the First Circuit · 1988
  4. Branerton Corp. v. CommissionerUnited States Tax Court · 1974
  5. Washington Bancorporation v. SaidDistrict Court, District of Columbia · 1992

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