Legal Opinion
United States v. Massachusetts Institute of Technology
Court of Appeals for the First Circuit
Decided November 25, 1997No. Nos. 97-1287, 97-1382PublishedCited by 118 opinions
1Opinion of the Court
BOUDIN, Circuit Judge.
This case concerns an attempt by the Massachusetts Institute of Technology to assert the attorney-client privilege and work-product doctrine in response to a document request by the Internal Revenue Service. The most important issue presented is whether MIT’s disclosure of certain of the documents to another government agency caused it to lose the privilege. The background facts are essentially undisputed.
MIT is a famous university with tax-exempt status under 26 U.S.C. § 501(c)(3). In 1993, the IRS conducted an examination of MIT’s records to determine whether MIT still…
2Cases cited23 opinions
- Upjohn Co. v. United StatesSupreme Court of the United States · 1981
- Fisher v. United StatesSupreme Court of the United States · 1976
- United States v. ZolinSupreme Court of the United States · 1989
- In Re Sealed CaseCourt of Appeals for the D.C. Circuit · 1982
- Diversified Industries, Inc. v. The Honorable James H. Meredith, Chief Judge of the United States District Court for the Eastern District of MissouriCourt of Appeals for the Eighth Circuit · 1978
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3Cited by118 opinions
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- In Re Columbia/Hca Healthcare Corporation Billing Practices LitigationCourt of Appeals for the Sixth Circuit · 2002
- Cavallaro v. United StatesCourt of Appeals for the First Circuit · 2002
- In Re Qwest Communications International Inc.Court of Appeals for the Tenth Circuit · 2006
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