Opinion for the Court filed by Circuit Judge WILLIAMS.
WILLIAMS, Circuit Judge:
This case presents issues concerning the scope and application of the attorney work product privilege under the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552 (1982 & Supp. III 1985).
The Internal Revenue Service ("IRS") has adopted a system of statistical sampling to audit large accounts. From the audit of a portion of the items in an account balance or in...
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