I’ve written a lot about sealing documents in Tax Court because it’s an evergreen. Many a petitioner comes to grief there, and not a few practitioners. I’ve seen motions seeking sealing do more harm than just riding head-down under cover of all the other pleadings and other documents.

Weidong Zhang, Docket No. 15356-20W, filed 9/25/25, being a whistleblower, gets special treatment. Section 6103, the guardian of taxpayer information, lifts the shield when needed for judicial or administrative proceedings pertaining to tax administration in Section 6103(h)(4).

Judge Rose E. (“Cracklin'”) Jenkins sets forth the safeguards when IRS hands over third-party or nonparty Section 6103 information to petitioners for trial prep.

“(w)henever petitioner intends to provide for trial preparation to any person(s) any Protected Documents, petitioner must first provide a copy of this Order to any such person(s), inform such person(s) that he or she must comply with the terms of this Order, and obtain on a copy of this Order the name, the business or home address of such person(s) at which service of process can generally be made during business hours, and the signature(s) of such person(s). Petitioner shall retain the signed copy of this Order until one year after the decision in this case becomes final within the meaning of section 7481(a). After petitioner has complied with the first sentence of this ordered paragraph, petitioner may provide for trial preparation to any person(s) described in the first sentence any Protected Documents.” Order, at p. 2.

Given the pace of Tax Court litigation, that holding period could be a very long time.

A docket search shows Weidong Zhang is pro se. Judge Jenkins doesn’t state who Weidong Zheng might have engaged to help with trial prep. If any is not covered by Section 7525 confidentiality or litigation prep privilege, I wonder what cover they have.