Opinion for the court filed Circuit Judge HARRY T. EDWARDS.
HARRY T. EDWARDS, Circuit Judge:
The issues raised by this appeal require this court's consideration for the first time whether certain records of the Internal Revenue Service ("IRS") may be withheld from public disclosure pursuant to Exemption 5 of the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552(b)(5). Exemption 5 of the FOIA protects "inter-agency or intra-agency memorandums or letters...
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