District Court Rejects IRS Claim to Tax Attorney Work-Product

September 11, 2007 The Legal Intelligencer

In a decision praised by tax practitioners and assailed by the IRS, United States v. Textron Inc., a district court has held that the work-product privilege allowed Textron Inc. to resist an IRS summons seeking to obtain memoranda and opinions prepared by Textron's in-house tax attorneys and outside counsel. The IRS has already indicated that it will likely appeal this decision.

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