IRS Gets 1st Circ. To Limit Work Product Privilege

Law360, New York (August 14, 2009, 4:28 PM EDT) -- Attorney work product privilege does not cover documents created in preparation of a company's corporate financial statements, the U.S. Court of Appeals for the First Circuit has ruled in overturning a decision for industrial company Textron Inc., whose subsidiary's deals caught the eye of the IRS.

A majority of the full First Circuit held on Thursday that the work product doctrine protecting documents in anticipation of litigation did not shield Textron's tax audit work papers from an IRS summons.

The appeals court said lawyers prepared the...
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