Shannahan v. Internal Revenue Service, No. 10-35204 (9th Cir. 2012)
Annotate this CasePlaintiff, an attorney who represented Steven Cheung and Linda Su Cheung, as well as two companies allegedly owned by the Cheungs, asked for documents on which certain tax assessments were based. At issue was whether plaintiff was entitled under the Freedom of Information Act (FOIA), 5 U.S.C. 552, to disclosure of the tax-related documents held by the IRS. The government resisted the disclosure of the documents because disclosure would "seriously impair Federal tax administration" within the meaning of 26 U.S.C. 6103(e)(7) and Exemption 3 of FOIA, and "could reasonably be expected to interfere with enforcement proceedings" within the meaning of Exception 7(A) of FOIA. The government also contended under the fugitive entitlement doctrine that the Cheungs had no right to disclosure under FOIA, whether or not the documents qualified under FOIA. The court affirmed the district court's holding that the documents were protected under Exemptions 3 and 7(A) and did not reach the fugitive disentitlement question.
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