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Evergreen Trading, LLC v. United States
United States Court of Federal Claims
80 Fed.Cl. 122 (2007)
Evergreen Trading, LLC (plaintiff) challenged tax penalties assessed against them for underpayments resulting from mischaracterized transactions. Evergreen resisted disclosing correspondence written to and from its accountant that accompanied documents about the transactions, claiming they were privileged.
Rule of Law
Holding and Reasoning (Allegra, J.)
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