Docket No. 14-1965-cv.

806 F.3d 34 (2015)

Georg F.W. SCHAEFFLER, Schaeffler Holding GMBH & Co. KG, INA-Holding Schaeffler GMBH & Co. KG, Schaeffler Holding, LP, Petitioners-Appellants, v. UNITED STATES of America, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided: November 10, 2015.

Attorney(s) appearing for the Case

M. Todd Welty ( Mark P. Thomas , Laura L. Gavioli , Richard D. Salgado , on the brief) Dentons US LLP, Dallas, TX, for Petitioners-Appellants.

Rebecca S. Tinio , Assistant United States Attorney ( Preet Bharara , United States Attorney for the Southern District of New York, Emily E. Daughtry , Assistant United States Attorney, New York, N.Y., of counsel), for Respondent-Appellee.

Amar Sarwal , Wendy Ackerman , Association of Corporate Counsel, Washington, DC, for Amicus Curiae Association of Corporate Counsel.

Kate Comerford Todd , Warren Postman, U.S. Chamber Litigation Center, Inc., Washington, DC, Robert A. Long , Reeves C. Westbrook , Marianna Jackson , Jason Yen, Covington & Burling LLP, Washington, DC, for Amicus Curiae Chamber of Commerce of the United States of America.

Before: WINTER, WALKER, and DRONEY, Circuit Judges.

Georg F.W. Schaeffler ("Mr. Schaeffler" or "Schaeffler") and associated entities ("Schaeffler Group") (collectively "appellants") appeal from Magistrate Judge Gorenstein's order denying a petition to quash an IRS summons.1 We conclude that: (i) the attorney-client privilege was not waived by appellants...


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