The Supreme Court this morning denied review in the case of Textron v. United States, a closely watched case testing the privacy of legal work papers. Without comment, the Court denied review, leaving in place a lower court decision that challengers said would threaten the relationship and candor between lawyers and clients.
In the Textron case, the 1st U.S. Circuit Court of Appeals ruled that tax accrual work papers, prepared by lawyers for auditors and others, were not protected by the work product privilege and should be turned over to the IRS. The tax agency sought the papers as part of a tax shelter investigation. Textron, represented by Williams & Connolly partner Kannon Shanmugam, filed a petition seeking review of the 1st Circuit decision in January.
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