Countryside Limited Partnership, CLP Holdings, Inc., Tax Matters Partner v. Commissioner

132 T.C. No. 17

UNITED STATES TAX COURT COUNTRYSIDE LIMITED PARTNERSHIP, CLP HOLDINGS, INC., TAX MATTERS PARTNER, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 3162-05, 22023-05, Filed June 8, 2009. 2176-08, 2178-08. R has moved to compel production of documents. Ps object, claiming that the documents are protected from disclosure by, among other privileges, the so-called federally authorized tax practitioner (FATP) privilege described in sec. 7525(a), I.R.C. We have determined that the FATP privilege applies, subject to R’s right to show the privilege does…