Martin v. Internal Revenue Service

857 F.2d 722 (1988)

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Martin v. Internal Revenue Service

United States Court of Appeals for the Tenth Circuit
857 F.2d 722 (1988)

Facts

Robert Martin (plaintiff) and three other men (coshareholders) were equity holders in Western Oil Marketing (Western Oil) and Industrial Energy Partners (Industrial Energy), both of which were treated as pass-through entities for tax purposes. Western Oil and Industrial Energy were the sole partners in Western Operating Joint Venture (Western Operating), also a pass-through entity. The Internal Revenue Service (IRS) (defendant) audited all three entities and sought adjustments to their tax returns. Because all three were pass-through entities, any adjustments to their returns would affect Martin’s and his coshareholders’ tax liabilities. Accordingly, the IRS also sought adjustments to the four men’s returns. All four men sought to file protests to contest the IRS’s adjustments to their individual returns. The IRS agent auditing Martin’s return told Martin that the IRS would justify its adjustment to his returns using the same positions as in his coshareholders’ returns. Through the Freedom of Information Act, Martin sought the portions of his coshareholders’ protests that concerned the adjustments to Western Oil’s, Industrial Energy’s, and Western Operating’s returns. The IRS resisted the disclosure, citing that the protests constituted tax-return information within the meaning of § 6103 of the Internal Revenue Code (code). Martin sued in district court to compel disclosure. The district court ordered the IRS to disclose the protests with redactions and denied the IRS’s motion to suspend disclosure until the IRS could appeal. The Tenth Circuit Court of Appeals granted the IRS’s motion for an emergency stay and granted an expedited appeal.

Rule of Law

Issue

Holding and Reasoning (Seymour, J.)

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