United States DC Circuit

Summary judgment for appellee, compelling appellant to disclose, inter alia, e-mails containing legal advice that lawyers in the office of the chief counsel sent to field personnel is affirmed over claims that: 1) the plain language of 26 U.S.C. section 6110 makes clear that such advice is not chief counsel advice; or, alternatively 2) if the language is ambiguous, that appellant has reasonably construed it to exclude the e-mails from chief counsel advice.

Appellate Information

• Argued 04/19/2007
• Decided 07/24/2007
• Published 07/24/2007

Judges

• Before HENDERSON, ROGERS and KAVANAUGH, Circuit Judges.

Court

• United States DC Circuit

Counsel

• For Appellant:
  
• Francesca U. Tamami, Attorney, United States Department of Justice, argued the cause for the appellant.  Jeffrey A. Taylor, United States Attorney, and Jonathan S. Cohen, Attorney, were on brief.  Michael J. Martineau, Attorney, entered an appearance.


• For Appellees:
  
• Cornish F. Hitchcock argued the cause for the appellee.  William A. Dobrovir was on brief.