Valero Energy Corp. v. United States

How courts have described this case

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

• explaining that privileges are \construe[d] narrowly because they are in derogation of the search for truth\
• noting that “[o]nly plans and arrangements with a significant— 16 as opposed to an ancillary—goal of avoiding or evading taxes count” as tax shelters
• noting limited scope of opinion as the government was merely 19 seeking information and not yet lodging accusations
• expressing skepticism that “rigamarole” of 16 transactions was necessary restructuring rather than attempt to “avoid paying taxes”
• preparing tax returns is an accounting rather than legal service; the information transmitted so that it might be used on a tax return is not privileged
• preparing tax returns is an accounting rather than legal service; the information transmitted so that it might be used on a tax return is not privileged

Source: CourtListener parenthetical corpus (CC0).