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U.S. v. TEXTRON INC. AND SUBSIDIARIES

No. 07-2631.

553 F.3d 87 (2009)

UNITED STATES, Petitioner, Appellant, v. TEXTRON INC. AND SUBSIDIARIES, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided January 21, 2009.

Attorney(s) appearing for the Case

Kevin J. O'Connor, with whom Nathan J. Hochman, Assistant Attorney General, Richard T. Morrison, Deputy Assistant Attorney General, Gilbert S. Rothenberg, David I. Pincus, Robert W. Metzler, Judith A. Hagley, Attorneys, Tax Division, Department of Justice, and Robert Clark Corrente, United States Attorney, was on brief for appellant.

John A. Tarantino, with whom Patricia K. Rocha, Adler Pollock & Sheehan P.C., Arthur L. Bailey, J. Walker Johnson, and Steptoe & Johnson LLP, was on brief for appellee.

David M. Brodsky, Robert J. Malionek, Adam J. Goldberg, Latham & Watkins LLP, Robin S. Conrad, Amar D. Sarwal, Susan Hackett, Senior Vice President and General Counsel, Attorneys for the Chamber of Commerce of the United States of America and Association of Corporate Counsel, as amicus curiae in support of Textron Inc.

Kevin L. Kenworthy, Alan I. Horowitz, and Miller & Chevalier Chartered, Attorneys for Financial Executives International, as amicus curiae in support of Textron Inc.

Before TORRUELLA, BOUDIN, Circuit Judges, and SCHWARZER, District Judge.

TORRUELLA, Circuit Judge.

The question presented by this appeal is whether the work-product doctrine protects documents prepared by Textron Inc. for the purpose of calculating tax reserve liability from production to the IRS pursuant to an investigative subpoena. Like other companies, Textron prepares "tax accrual workpapers" which, generally speaking, list the questionable positions Textron took on its tax returns, estimate the likelihood that those positions will...

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