Legal Opinion
United States v. Textron Inc. & Subsidiaries
Court of Appeals for the First Circuit
Decided August 13, 2009No. 07-2631PublishedCited by 61 opinions
1Opinion of the Court
OPINION EN BANC
BOUDIN, Circuit Judge.
The question for the en bane court is whether the attorney work product doctrine shields from an IRS summons “tax accrual work papers” prepared by lawyers and others in Textron’s Tax Department to support Textron’s calculation of tax reserves for its audited corporate financial statements. Textron is a major aerospace and defense conglomerate, with well over a hundred subsidiaries, whose consolidated tax return is audited by the IRS on a regular basis. To understand the dispute, some background is required concerning financial statements, contingent tax…
2Cases cited20 opinions
- Hickman v. TaylorSupreme Court of the United States · 1947
- National Labor Relations Board v. Sears, Roebuck & Co.Supreme Court of the United States · 1975
- Coastal States Gas Corporation v. Department of EnergyCourt of Appeals for the D.C. Circuit · 1980
- Grosso v. United StatesSupreme Court of the United States · 1968
- Clark v. United StatesSupreme Court of the United States · 1933
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3Cited by61 opinions
- Vicor Corp. v. Vigilant InsuranceCourt of Appeals for the First Circuit · 2012
- United States v. Deloitte LLPCourt of Appeals for the D.C. Circuit · 2010
- Menominee Indian Tribe of Wisconsin v. United StatesCourt of Appeals for the D.C. Circuit · 2010
- Lluberes v. UNCOMMON PRODUCTIONS, LLCCourt of Appeals for the First Circuit · 2011
- Kolbe v. BAC Home Loans Servicing, LPCourt of Appeals for the First Circuit · 2013
56 more not listed; retrieve them via the Exa API.