Legal Opinion
Delaney, Migdail & Young, Chartered v. Internal Revenue Service
Court of Appeals for the D.C. Circuit
Decided August 21, 1987No. 86-5068PublishedCited by 90 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge WILLIAMS.
WILLIAMS, Circuit Judge:
This case presents issues concerning the scope and application of the attorney work product privilege under the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552 (1982 & Supp. III 1985).
The Internal Revenue Service (“IRS”) has adopted a system of statistical sampling to audit large accounts. From the audit of a portion of the items in an account balance or in a class of transactions, the IRS infers conclusions as to the entire balance or class. Before adopting the program, it had its attorneys prepare two…
2Cases cited12 opinions
- Hickman v. TaylorSupreme Court of the United States · 1947
- Upjohn Co. v. United StatesSupreme Court of the United States · 1981
- National Labor Relations Board v. Sears, Roebuck & Co.Supreme Court of the United States · 1975
- Robert G. Vaughn v. Bernard Rosen, Executive Director, United States Civil Service CommissionCourt of Appeals for the D.C. Circuit · 1973
- Mead Data Central, Inc. v. United States Department of the Air ForceCourt of Appeals for the D.C. Circuit · 1977
7 more not listed; retrieve them via the Exa API.
3Cited by90 opinions
- Safecard Services, Inc. v. Securities and Exchange CommissionCourt of Appeals for the D.C. Circuit · 1991
- United States v. Monroe Adlman, as Officer and Representative of Sequa CorporationCourt of Appeals for the Second Circuit · 1998
- John R. Mapother, Stephen E. Nevas v. Department of JusticeCourt of Appeals for the D.C. Circuit · 1993
- Arthur M. Schiller v. National Labor Relations BoardCourt of Appeals for the D.C. Circuit · 1992
- Karl Gallant v. National Labor Relations BoardCourt of Appeals for the D.C. Circuit · 1994
85 more not listed; retrieve them via the Exa API.