United States v. Textron

507 F. Supp. 2d 138 (2007)

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United States v. Textron

United States District Court for the District of Rhode Island
507 F. Supp. 2d 138 (2007)

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Facts

The Internal Revenue Service (IRS) (plaintiff) issued a summons to Textron, Inc. (defendant) requesting hundreds of documents in connection with an audit of the corporation. Textron complied with every request except one for Textron’s tax-accrual work papers (the work papers). The work papers contained a list of items in Textron’s tax returns identified by Textron’s counsel to be based on questionable areas of law and at risk of being challenged by the IRS; estimates of Textron’s chance of prevailing on each item; and the amount of money reserved in the event of litigation. The purpose of the work papers was to ensure Textron had adequate funds set aside in the event of litigation. The work papers did not contain factual information or documents. Textron hired an independent auditor to confidentially review the work papers to ensure Textron’s compliance with Securities and Exchange Commission regulations. After Textron refused to produce the work papers in response to the IRS’s summons, the IRS filed a petition to enforce the summons. Textron argued that the work papers were privileged.

Rule of Law

Issue

Holding and Reasoning (Torres, J.)

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