Federal District Judge for the District of Columbia Rosemary M. Collyer has ruled that the Internal Revenue Service ("IRS") can withhold the names of third parties contacted in an audit as well as notes taken during the interviews and the information they provided to the IRS. The judge held that the names were withholdable pursuant to FOIA Exemption 7(C). The notes and information provided by the third parties were held withholdable pursuant to Exemption 7(A).
As Exemption 7(A) is temporal and only lasts as long as the audit or subsequent prosecution (if there is one) is open, these documents may be subject to further requests in the future.
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