Opinion for the Court filed by Circuit Judge BROWN.
BROWN, Circuit Judge:
In this appeal, the parties dispute whether disclosure of certain Internal Revenue Service ("IRS") settlement information could risk "circumvention of the law"—a category exempted from disclosure under the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552. Id. § 552(b)(7)(E). On cross-motions for summary judgment, the district court held the settlement information...
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