Fifth Circuit Rules that Vaughn Index is Necessary to Withhold Documents

The United States Court of Appeals for the Fifth Circuit has ruled that the IRS did not adequately explain its witholdings and must provide a Vaughn index when in litigation before it can have a Court rule that it properly withheld documents.  The Court explains in detail why a Vaughn index or a similar document that specifically explains why documents have been withheld are necessary.  The Court also explains why conclusory statements by the government are not enough to warrant a Court finding that the government met its burden of proof in establishing that it properly withheld documents.