The trusty attorneys for Seabrook Property, LLC, Seabrook Manager, LLC, Tax Matters Partner, Docket No. 5071-21, filed 6/15/23, are true believers in the “Win Your Case at Discovery” tactic, hawked far and wee by every CLEflogger. They’re trying it again, as Little Horse Creek Property’s conserved and easemented land, which twice heretofore appeared on this my blog before the Little Horses stiped out two (count ’em, two) years ago, was a mere thirty miles from the Seabrooks’ Dixieland Boondocks.

So the Seabrooks want the entire IRS file on the Little Horses.

Nuttin’ doin’, says Judge Emin (“Eminent”) Toro, although his language is much more elegant than mine and features somber reasoning and copious citation of precedent.

I’d be a lot more specific, with substantial swaths of Judge Eminent’s learned discussion embedded herein, but again the Genius Baristas have barred me (and everyone else) from cut-and-paste or drag-and-drop.

So I can only direct you to pages 1-2 for breadth of scope of discovery, page 3 thereof for a discussion of disparate treatment of taxpayers as irrelevant, and pages 3-4 for the role of Section 6103 in protecting taxpayer info, and the breadth of scope of such info.

As for this trend of blocking access to text, is it AI they’re worried about? Post-Avianca, a 2 Cir demolition of a 30-year NY State courtier, no attorney in his/her right mind would trust AI for legal research. As for fraudsters generating phony orders and opinions, there’s been cheap software that lets them deskew and tamper for more than twenty years, and to my knowledge, but without having made an independent investigation, no one has done so.

So c’mon, Genius Baristas, do as The Hombres did and let it all hang out