United States Second Circuit

In a tax action seeking to quash an IRS summons, the district court's denial of plaintiff's petition to quash is reversed where: 1) plaintiff did not waive attorney-client privilege by providing documents to a consortium of banks sharing a common legal interest in tax treatment of plaintiff's refinancing and corporate restructuring; and 2) the work-product doctrine protects documents analyzing the tax treatment of refinancing and restructuring prepared in anticipation of litigation with the IRS.

Appellate Information

• Decided 11/10/2015
• Published 11/10/2015

Judges

• WINTER

Court

• United States Second Circuit

Counsel