§2025

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2 Citing Cases

ake a showing beyond the substantial need/undue hardship test required under Rule 26(b) (3) for non-opinion work product. Upiohn Co. v. United States, 449 U.S. 383, 401-02, 101 S.Ct. 677, 688-89, 66 L.Ed.2d 584 (1981). 7 See Wright, Miller & Marcus, sec. 2025, nn. 3, 4, and 5. - 14 - The Supreme Court, however, has so far declined to - decide whether opinion work product is absolutely protected from discovery._ Id. at 401, 101 S.Ct. at 688. We agree with the several courts and commentators that

Ratke v. Commissioner 129 T.C. 45 · 2007

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