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HAMBARIAN v. COMMISSIONER

Docket Nos. 11856-99, 7973-00, 3042-01, 3101-01.

118 T.C. 565 (2002)

118 T.C. No. 35

JEFFREY HAMBARIAN AND VIRGINIA M. HAMBARIAN, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 13, 2002.

Attorney(s) appearing for the Case

Mark M. Hathaway and James D. McCarthy, Jr., for petitioners.

Louis B. Jack and Nicholas J. Richards, for respondent.

OPINION

GERBER, Judge:

Respondent moved to compel the discovery of documents and computer searchable electronic media from petitioners. The documents were obtained by Jeffrey Hambarian's (petitioner's) defense attorneys in a criminal case. Petitioners refused to turn over the documents, asserting the protection of the work product doctrine. In particular, we consider whether the selection of particular documents...

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