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U.S. v. WEALTH AND TAX ADVISORY SERVICES, INC.

No. 06-55915.

526 F.3d 528 (2008)

UNITED STATES of America, Plaintiff-Appellant, v. WEALTH AND TAX ADVISORY SERVICES, INC., Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed May 15, 2008.

Attorney(s) appearing for the Case

Eileen J. O'Connor, Robert W. Metzler, and Gretchen M. Wolfinger, United States Department of Justice, Washington, D.C., for the plaintiff-appellant.

David Jacobs and Deanna L. Ballesteros, Epstein Becker & Green, Los Angeles, CA, for the defendant-appellee.

Before: CYNTHIA HOLCOMB HALL, T.G. NELSON, and BARRY G. SILVERMAN, Circuit Judges.

PER CURIAM:

We hold today that a 29-page "draft opinion letter" sent by the taxpayers' accountants to the taxpayers' tax lawyers, containing extensive legal authority and analysis of a complicated tax transaction, constitutes a "memorandum." Therefore, even though the letter was characterized as a "draft," it was nevertheless subject to disclosure pursuant to the taxpayers' agreement to provide to the IRS "[a]ll opinions...

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