Tax Court on work product protection for IRS attorneys in sanctoins and attorneys fees context

TaxProfBlog and Bryan Camp (Texas Tech) point to Ratke v. Commissioner, 129 T.C. No. 6 (9/5/07).  This case seems to hold that in the context of a “dispute over attorneys fees and possible sanctions against the IRS trial attorney” the best a taxpayer can do is get in camera review of a “trial memo” (sent by the attorneys to DC).  I am not sure where I need to put this into my “brain file.”