Legal Opinion

Commissioner of Revenue v. Comcast Corp.

Massachusetts Supreme Judicial Court

Decided March 3, 2009PublishedCited by 47 opinions

1Opinion of the CourtMarshall, C.J.

We transferred this appeal here on our own motion to consider whether the attorney-client privilege or the work product doctrine protect from disclosure communications between an in-house corporate counsel and outside tax accountants consulted by him regarding the structuring of a sale of stock mandated by an antitrust consent judgment.

In connection with an audit examination by the Commissioner of Revenue (commissioner)2 of Comcast Corporation’s (Comcast’s)3 corporate excise tax returns for the tax period November 1, 1996, through December 31, 1997, the commissioner is investigating whether…

2Cases cited48 opinions

  1. Hickman v. TaylorSupreme Court of the United States · 1947
  2. Upjohn Co. v. United StatesSupreme Court of the United States · 1981
  3. United States v. Louis KovelCourt of Appeals for the Second Circuit · 1961
  4. United States v. Arthur Young & Co.Supreme Court of the United States · 1984
  5. United States v. Monroe Adlman, as Officer and Representative of Sequa CorporationCourt of Appeals for the Second Circuit · 1998

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3Cited by47 opinions

  1. Vicor Corp. v. Vigilant InsuranceCourt of Appeals for the First Circuit · 2012
  2. Global Investors Agent Corp. v. National Fire InsuranceMassachusetts Appeals Court · 2010
  3. Commonwealth v. FitzpatrickMassachusetts Supreme Judicial Court · 2012
  4. Clair v. ClairMassachusetts Supreme Judicial Court · 2013
  5. Commonwealth v. GelfgattMassachusetts Supreme Judicial Court · 2014

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