OPINION
HALL, Judge:
On April 29, 1980, the Bank of America N.T. & S.A. (the bank) filed a motion for protective order pursuant to Rule 147(b), Tax Court Rules of Practice and Procedure, requesting the Court to order respondent to compensate the bank for all reasonable costs incurred in connection with the production of additional documents in this case. A brief summary of the prior procedural motions involved in this case is necessary in order...
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