Dynamo Holdings Limited Partnership v. Commissioner of Internal Revenue

143 T.C. No. 9, 2014 WL 4636526 (2014)

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Dynamo Holdings Limited Partnership v. Commissioner of Internal Revenue

United States Tax Court
143 T.C. No. 9, 2014 WL 4636526 (2014)

RW

Facts

Dynamo Holdings Limited Partnership (Dynamo) (plaintiff) and the Internal Revenue Service (IRS), through the commissioner of Internal Revenue (defendant), were engaged in litigation before the United States Tax Court. During electronic discovery (e-discovery), Dynamo offered to use the predictive-coding form of technology-assisted review to identify and produce relevant and discoverable electronically stored information (ESI) from its backup tapes. The IRS objected that predictive coding was an unproven technology. The IRS moved to compel production, insisting that Dynamo either search each item of ESI on its backup tapes, at about seven times the cost of predictive coding, or turn the tapes over and let the IRS perform the search itself, subject to a clawback provision to protect Dynamo’s privileged ESI. At the hearing on the IRS’s motion to compel, the court heard expert testimony that predictive coding was inexpensive, reliable, and widely used in the technology industry, for example, to screen spam from Internet users’ email accounts.

Rule of Law

Issue

Holding and Reasoning (Buch, J.)

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