Legal Opinion
United States v. Roxworthy
Court of Appeals for the Sixth Circuit
Decided August 10, 2006No. 05-5776PublishedCited by 114 opinions
1Opinion of the Court
OPINION
R. GUY COLE, JR., Circuit Judge.
Defendant Patrick J. Roxworthy, in his capacity as Vice President of Tax at Yum! Brands, Inc. (‘Yum”), appeals the district court’s order enforcing an Internal Revenue Service (IRS) administrative summons demanding production of two memoranda that Yum argues are protected by work product privilege. For the reasons set forth below, we reverse the district court’s order to compel their production and remand to the district court for entry of an order granting Roxworthy’s motion to quash.
I
The IRS is conducting an investigation of Yum’s tax liability for…
2Cases cited21 opinions
- Hickman v. TaylorSupreme Court of the United States · 1947
- Coastal States Gas Corporation v. Department of EnergyCourt of Appeals for the D.C. Circuit · 1980
- Senate of the Commonwealth of Puerto Rico on Behalf of Judiciary Committee v. United States Department of JusticeCourt of Appeals for the D.C. Circuit · 1987
- United States v. Monroe Adlman, as Officer and Representative of Sequa CorporationCourt of Appeals for the Second Circuit · 1998
- In Re Grand Jury Proceedings. Appeal of Fmc Corporation, Douglas E. Kliever and Cleary, Gottlieb, Steen & HamiltonCourt of Appeals for the Third Circuit · 1979
16 more not listed; retrieve them via the Exa API.
3Cited by114 opinions
- Biegas v. Quickway Carriers, Inc.Court of Appeals for the Sixth Circuit · 2009
- Gruenbaum v. Werner Enterprises, Inc.District Court, S.D. Ohio · 2010
- In Re Professionals Direct InsuranceCourt of Appeals for the Sixth Circuit · 2009
- United States v. Textron Inc. & SubsidiariesCourt of Appeals for the First Circuit · 2009
- Invesco Institutional (N.A.), Inc. v. PaasDistrict Court, W.D. Kentucky · 2007
109 more not listed; retrieve them via the Exa API.