Solers, Inc. v. IRS

Solers challenges the IRS’ response to its request for documents under the Freedom of Information Act (FOIA), 5 U.S.C. 552. The district court granted summary judgment for the IRS. The court concluded that the issue of whether the IRS provided a Vaughn index sufficient to enable the district court to evaluate the IRS’ claimed exemptions became irrelevant and moot after the IRS complied with the district court’s order to produce the records for in camera review and the district court completed its own review of the records. The district court sustained the IRS' position that Exemptions 3, 5, 6, and 7(C) applied to the following four categories: (1) the agent’s handwritten notes; (2) the summary report, graph, and checksheet; (3) the activity record; and (4) the two emails. The court affirmed the judgment. View "Solers, Inc. v. IRS" on Justia Law