OPINION
WELLS, Chief Judge:
The instant case is before us on petitioner's motion for a protective order, motion to strike, and motion for leave to file reply to respondent's objection to petitioner's motion for protective order.
Background
During August 2001, the tax matters partner (TMP) of Schneider Interests, L.P. (the partnership), received notice from respondent that the partnership's tax year ended December 31, 1997...
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