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U.S. Court of Appeals Rules That IRS is Entitled to Tax Accrual Work Papers |
August 20, 2009
In a highly controversial 3-2 decision, the United States Court of Appeals for the First Circuit ruled in United States v. Textron, Inc., 2009 U.S. App. LEXIS 18103 (1st Cir. Aug. 13, 2009), that the work product privilege does not protect a company's tax accrual work papers from IRS discovery. The First Circuit concluded that tax accrual work papers are not work product, because they are prepared to support a company's financial statements and gain auditor approval, rather than "for use in possible litigation." Textron is an important decision that may have far-reaching implications, particularly for publicly traded companies.
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The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance. |
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