Thomas J. and Bonnie F. Ratke v. Commissioner

129 T.C. No. 6

UNITED STATES TAX COURT THOMAS J. AND BONNIE F. RATKE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 9641-01L. Filed September 5, 2007. After this Court ruled for Ps in the instant collection case, Ps moved for an award of costs under sec. 7430, I.R.C. 1986, and then for sanctions under sec. 6673(a)(2), I.R.C. 1986. In connection with these motions, Ps seek discovery of (1) a memorandum sent by R’s initial trial counsel to R’s national office at the time R’s answer was filed in the instant case and (2) the unredacted version of the responding memorandum…