The gist of this is that a tax attorney prepared some accounting schedules and does not want to release them to the IRS. An opinion from the 1st Circuit says that work product is not covered by Attorney-Client Privlege.
My money says this is going to be overturned when it gets to Johnny and the Supremes.
Below is one paragraph from the opinion on FindLaw. You can read the opinion and the dissent at tinyurl.com/nqm9r8.
Those of you are are suspicious of Nu Yawkers should take note the FindLaw is far enough away from Nu Yawk City that even people on the Georgia-Alabama Line should feel safe.
"To sum up, the work product privilege is aimed at protecting work done for litigation, not in preparing financial statements. Textron's work papers were prepared to support financial filings and gain auditor approval; the compulsion of the securities laws and auditing requirements assure that they will be carefully prepared, in their present form, even though not protected; and IRS access serves the legitimate, and important, function of detecting and disallowing abusive tax shelters."
Dick