Valero Energy Corp. v. United States

EVANS, Circuit Judge.

In this appeal, Valero Energy Corporation asks us to take a close look at the tax practitioner-client privilege. Valero sought to protect several documents under this privilege, and the result was a mixed bag — some documents were shielded from the Internal Revenue Service, while others were not. Valero now contends that by reaching this decision, the district court misconstrued not only the privilege, but also an exception to the privilege, which grants the government access to certain documents when tax shelters are promoted.

Valero is a large company involved in crude…