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UNITED STATES v. DEPT. OF INS.

No. 21-3008.

66 F.4th 114 (2023)

UNITED STATES of America, v. State of Delaware DEPARTMENT OF INSURANCE, Appellant.

United States Court of Appeals, Third Circuit.

(Filed April 21, 2023).

Attorney(s) appearing for the Case

James J. Black, III , [ARGUED], Mark W. Drasnin , Jeffrey B. Miceli , Black & Gerngross, 1617 John F. Kennedy Blvd., Suite 1575, Philadelphia, PA 19103, Patricia A. Davis , Office of Attorney General of Delaware, Delaware Department of Justice, 102 West Water Street — 3rd Floor, Dover, DE 19904, Kathleen P. Makowski , Office of Attorney General of Delaware, Department of Justice, 820 N. French Street — Suite 1010, Wilmington, DE 19801, Counsel for Appellants.

Travis S. Hunter , Richards Layton & Finger, 920 N. King Street, One Rodney Square, Wilmington, DE 19801, Counsel for Amicus Appellants.

Ward W. Benson , Kyle L. Bishop , United States Department of Justice, Tax Division, P.O. Box 227, Ben Franklin Station, Washington, DC 20044, Michael J. Haungs , Lauren E. Hume , Francesca Ugolini , [ARGUED], United States Department of Justice, Tax Division, 950 Pennsylvania Avenue, P.O. Box 502, Washington, DC 20044, Counsel for Appellee.

Before: JORDAN, SCIRICA, and RENDELL, Circuit Judges.

OPINION OF THE COURT

This case pits Delaware's authority to protect corporate privacy against the power of the IRS to enforce the tax laws of the United States. The dispute arises from the refusal of the Delaware Department of Insurance (the "Department") to comply with an IRS summons. The Department relies on Title...

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