It's Not Over Until the First Circuit Sings

The Tax Prof Blog reports that the First Circuit has granted rehearing in the infamous Textron Case denying the Government's attempt to summons tax accrual workpapers -- the tax mother lode for the IRS. The Tax Prof Blog report may be reviewed here (along with links to the opinion and some commentary on the opinion). Prediction: The Government will get the workpapers. Perhaps we'll write more on this later; perhaps not.