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SHANNAHAN v. I.R.S.

Nos. 10-35204, 10-35244.

672 F.3d 1142 (2012)

William P. SHANNAHAN, Plaintiff-Appellant, v. INTERNAL REVENUE SERVICE, a federal agency, Defendant-Appellee. William P. Shannahan, Plaintiff-Appellant, v. Internal Revenue Service, a federal agency, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed March 13, 2012.

Attorney(s) appearing for the Case

Samuel Ryan Castic , David John Lenci , Michael K. Ryan , K & L Gates LLP, Seattle, WA, for the appellant.

Randolph Lyons Hutter , Carmen M. Banerjee , Jonathan S. Cohen , Nicole Maria Elliott, United States Department of Justice, Washington, D.C., Robert P. Brouillard , Office of the United States Attorney, Seattle, WA, for the appellee.

Before: STEPHEN REINHARDT, WILLIAM A. FLETCHER, and JOHNNIE B. RAWLINSON, Circuit Judges.

OPINION

W. FLETCHER, Circuit Judge:

We are asked to decide whether appellants are entitled under the Freedom of Information Act ("FOIA") to disclosure of tax-related documents held by the Internal Revenue Service ("IRS"). The government resisted the disclosure of the documents on two grounds. First, it contended that disclosure of the documents would "seriously impair Federal tax administration" within the meaning of 26 U.S.C. § 6103(e)(7) and Exemption...

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