On August 13, 2009, the First Circuit in United States v. Textron Inc. held that tax accrual workpapers are not protected from discovery under the attorney work-product privilege. In so doing, the court eviscerated the last line of protection for dual-purpose tax documents from the prying eyes of the IRS and opposing parties in litigation.
Kerry L. Killeen, Hand Over Your Tax Accrual Workpapers: The First Circuit in United States v. Textron Exposes Dual-Purpose Documents to Discovery, 52 B.C.L. Rev. E. Supp. 1 (2011), http://lawdigitalcommons.bc.edu/bclr/vol52/iss6/2