The IRS summons in United States v. Textron, 507 F.Supp.2d 138 (D.R.I. 2007), sought the corporation’s tax accrual workpapers. Textron claimed that the workpapers were privileged because they included, inter alia, estimates by Textron’s counsel expressing, in percentages, their judgments regarding Textron’s chances of prevailing in any litigatio ...
The IRS summons in United States v. Textron, 507 F.Supp.2d 138 (D.R.I. 2007), sought the corporation’s tax accrual workpapers. Textron claimed that the workpapers were privileged because they included, inter alia, estimates by Textron’s counsel expressing, in percentages, their judgments…