Federal Tax

Obtaining Information from the Government in Discovery and Disclosure-Related Damages Actions Against the Government (Portfolio 626)

  • This Portfolio discusses the scope of discovery and the discovery tools available to a taxpayer in the context of civil tax litigation in the federal district courts, the U.S. Tax Court, and the U.S. Court of Federal Claims.

Description

Bloomberg Tax Portfolio, Obtaining Information from the Government in Discovery and Disclosure – Related Damages Actions Against the Government, discusses the scope of discovery and the discovery tools available to a taxpayer in the context of civil tax litigation in the federal district courts, the U.S. Tax Court, and the U.S. Court of Federal Claims.
Specifically, it outlines the government defenses to discovery, including the attorney-client privilege, attorney work product doctrine and deliberative process as well as damages actions that can be brought against the government to remedy unlawful disclosures and other violations of taxpayer privacy.
The discovery for specific actions or issues, and internal limitations on IRS responses to discovery is also discussed.

Table of Contents

I. Discovery Against the Government in Civil Tax Litigation
II. Discovery for Specific Actions or Issues
III. Discovery for Specific Actions or Issues
IV. Internal Limitations on IRS Responses to Discovery
V. Government Liability for Unauthorized Disclosures

Christopher-Murphy
Christopher Murphy
Skadden Arps LLP
Neeraj Pai
Neeraj Pai
Counsel
Sidley Austin LLP
Philip MacWilliams
Philip MacWilliams
Department Of Justice