Opinion for the Court filed by Circuit Judge SENTELLE.
SENTELLE, Circuit Judge:
Tax Analysts, a publisher of tax material, sued the Internal Revenue Service (IRS) and the Christian Broadcasting Network (CBN) under the Freedom of Information Act (FOIA), 5 U.S.C. § 552 (1994), and Internal Revenue Code (I.R.C.) § 6104, 26 U.S.C. § 6104 (1994), respectively, in an effort to obtain copies of a closing agreement reached between the IRS and CBN in...
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