A party seeking disclosure of tax returns must make a strong showing that the information contained in the returns is necessary and unavailable from other sources. However, the underlying financial information which is contained in documents other than tax returns, such as in Form K-1s, is discoverable.
Norddeutsche Landesbank Girozentrale v. Tilton, NY Slip Op 06633 (1st Dep't October 4, 2018)
Here is the decision.
