MEMORANDUM OPINION
GERBER, Judge:
We must decide: (1) Whether, in a pretrial discovery setting, it was appropriate for respondent to refuse to produce a document on the ground that petitioner is not entitled to go behind the notice of deficiency determination, and (2) whether petitioner is entitled to discover a pre-deficiency-notice report of respondent's expert who will not be called as a witness.
Background
Petitioner moved to...
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