Dynamo Holdings Ltd. Partnership v. Commissioner
United States Tax Court
R requests that Ps produce electronically stored information contained on two backup storage tapes or, alternatively, the tapes themselves (or copies thereof). Ps acknowledge that the tapes contain tax-related information but assert that the tapes also contain privileged information that Ps have a right or duty to protect.
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R requests that Ps produce electronically stored information contained on two backup storage tapes or, alternatively, the tapes themselves (or copies thereof). Ps acknowledge that the tapes contain tax-related information but assert that the tapes also contain privileged information that Ps have a right or duty to protect. Ps assert that they must review the responsive information on the tapes before giving the information to R to ensure that privileged or confidential information is not disclosed. Ps request that the Court let them use "predictive coding", a technique prevalent in the…
1Opinion of the Court
OPINION
Buen, Judge:
These consolidated cases are before the Court on respondent’s motion to compel production of documents. 1 The cases concern various transfers from Beekman Vista, Inc. (Beekman), to a related entity, Dynamo Holdings Limited Partnership (Dynamo). Respondent determined that the transfers are disguised gifts to Dynamo’s owners. Petitioners assert that the transfers are loans.
Respondent requests that petitioners produce the electronically stored information (ESI) contained on two specified backup storage tapes or, alternatively, that they produce the tapes themselves (or copies…
2Cases cited6 opinions
- Zubulake v. UBS Warburg LLCDistrict Court, S.D. New York · 2003
- Zaentz v. CommissionerUnited States Tax Court · 1979
- Branerton Corp. v. CommissionerUnited States Tax Court · 1975
- Rutter v. CommissionerUnited States Tax Court · 1983
- Moore v. Publicis GroupeDistrict Court, S.D. New York · 2012
1 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Dynamo Holdings Limited Partnership, Dynamo, GP, Inc., Tax Matters Partner v. CommissionerUnited States Tax Court · 2018
- Dynamo Holdings Limited Partnership, Dynamo, GP, Inc., Tax Matters Partner v. CommissionerUnited States Tax Court · 2014
- Paul Berger v. Graf Acquisition, LLCCourt of Chancery of Delaware · 2024
- Whistleblower 11099-13W v. Comm'rUnited States Tax Court · 2016