Oneida, Ltd. v. United States

ORDER

ALLEGRA, Judge.

Plaintiff, Oneida, Ltd. & Subsidiaries, filed this tax refund suit on January 30, 1997, seeking a refund of taxes and interest allegedly overpaid for tax years 1988 and 1989. At issue is defendant’s motion to compel the production of certain documents that were requested, via subpoena and otherwise, from plaintiffs testifying expert witnesses. Plaintiff claims that the documents are protected from production by the work product doctrine. Defendant argues that the work product doctrine does not apply to the subject documents and even if it did, plaintiff waived the doctrine…