Alan Horowitz discusses the decision by the Supreme Court not to review the First Circuit’s ruling in Textron v. United States. Horowitz, who served as counsel for Financial Executives International on its amicus brief in support of Supreme Court review, said that it is fortunate that other circuits have not adopted the First Circuit's "novel" approach. He said Textron affects not only tax accrual work papers, but other non-tax assessments that are commonly made by business lawyers.