Schaeffler v. United States
Court of Appeals for the Second Circuit
1Opinion of the Court
WINTER, Circuit Judge:
Georg F.W. Schaeffler (“Mr. Schaeffler” or “Schaeffler”) and associated entities (“Schaeffler Group”) (collectively “appellants”) appeal from Magistrate Judge Gor-enstein’s order denying a petition to quash an IRS summons. 1 We conclude that: (i) the attorney-client privilege was not waived by appellants’ provision of documents to a consortium of banks (“Consortium”) sharing a common legal interest in the tax treatment of a refinancing and corporate restructuring resulting from an ill-fated acquisition originally financed by the Consortium; and (ii) the work-product…
2Cases cited16 opinions
- Hickman v. TaylorSupreme Court of the United States · 1947
- United States v. Monroe Adlman, as Officer and Representative of Sequa CorporationCourt of Appeals for the Second Circuit · 1998
- In Re Grand Jury Subpoena Duces Tecum Dated September 15, 1983 Marc Rich & Co. A.G., Intervenor-Appellant v. United StatesCourt of Appeals for the Second Circuit · 1984
- In Re: Grand Jury Proceedings United States of America v. John DoeCourt of Appeals for the Second Circuit · 2000
- United States v. Martin SchwimmerCourt of Appeals for the Second Circuit · 1989
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3Cited by81 opinions
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- American Civil Liberties Union v. United States Department of JusticeDistrict Court, S.D. New York · 2016
- Bagley v. Yale UniversityDistrict Court, D. Connecticut · 2016
- American Civil Liberties Union v. United States Department of JusticeDistrict Court, S.D. New York · 2017
- Bloomingburg Jewish Education Center v. Village of BloomingburgDistrict Court, S.D. New York · 2016
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