Tax Analysts v. Internal Revenue Service

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that general legal analysis and policy information in IRS Field Service Advice Memoranda is not protected under Section 6103
• holding that IRS could redact “true return information” from certain documents but that legal analyses therein did not qualify as “return information”
• holding that the IRS could redact “true return information” from certain field memoranda, but that the legal analyses contained in the memoranda were not exempt “return information”
• holding that the Internal Revenue Service could not invoke the attorney-client privilege to shield documents prepared by its counsel “when the counsel rendering the legal opinion in effect is making law”
• observing that “the meaning of FOIA should be the same no matter which agency is asked to produce records”
• noting that work product doctrine applies to documents prepared in anticipation of litigation that reflect legal theories and opinions of counsel

Source: CourtListener parenthetical corpus (CC0).