Whelan v. Buffalo Mun. Hous. Auth.

How courts have described this case

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

• holding that IRS civil tax audit is not a judicial proceeding within the meaning of federal rule allowing disclosure of matters occurring before a grand jury
• holding that disclosure of grand jury materials to IRS to allow it to determine tax liability was not permitted under Rule 6(e)
• holding that disclosure of grand jury materials to IRS to allow it to determine tax liability was not permitted under Rule 6(e)
• holding that disclosure for use in a tax audit was not “preliminarily to or in connection with a judicial proceeding” within the meaning of then Rule 6(e)(3)(c)(i), now 6(e)(3)(E)(i)
• recognizing conjunctive nature of judicial proceeding and particularized need requirements for disclosure of grand jury matters
• explaining that courts can consider Rule 6(e) motions when primary purpose of disclosure is to prepare an anticipated judicial matter

Source: CourtListener parenthetical corpus (CC0).