Paul L. Caron
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Wednesday, July 25, 2007

Tax Analysts Prevails in D.C. Circuit, Forces Disclosure of Office of Chief Counsel E-mails

The D.C. Circuit yesterday held that the IRS must disclose e-mail containing legal advice rendered in less than two hours by lawyers in the Office of the Chief Counsel and sent to field personnel. Tax Analysts v. IRS, No. 06-5136 (D.C. Cir. 7/24/07). The D.C, Circuit affirmed the district court's holding that the email constituted "chief counsel advice" (CCA) which the IRS is required to disclose under § 6110.  The D.C. Circuit concluded that § 6110 "requires no particular form or formality. Nor does it distinguish between advice a lawyer renders in less than two hours and advice that takes longer than two hours to prepare."

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Tax Analysts is a commercial publisher that has a rather successful track record of suing the IRS to obtain its inside information.Now, to be sure the IRC has a number of self-contained disclosure provisions, so there isn’t much of a [Read More]

Tracked on Jul 25, 2007 5:56:37 AM

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