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STERLING TRADING OPPORTUNITIES, L.L.C. v. COMMISSIONER

Dkt. Nos. 12361-05, 12629-05.

94 T.C.M. 458 (2007)

T.C. Memo. 2007-339

Sterling Trading Opportunities, L.L.C., Sentinel Advisors, L.L.C., Tax Matters Partner v. Commissioner. Topaz Trading, L.L.C., Sentinel Advisors, L.L.C., Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed November 14, 2007.

Attorney(s) appearing for the Case

Felix B. Laughlin and Mark D. Allison, for petitioner.

Bryan C. Skarlatos and Christopher M. Ferguson, for participating partner. James E. Gray, respondent.

MEMORANDUM OPINION

HALPERN, Judge:

Respondent has moved to compel production of documents (the motion). Participating partner AS/EI Investments, L.L.C. (the L.L.C.), and petitioner object. L.L.C. has, under seal and for in camera inspection, submitted to the Court four documents (the documents), which are at the center of the dispute, along with a memorandum in support of its and petitioner's claim of work product protection for the documents. The L.L.C...

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