Kevin Kenworthy discusses the 1st U.S. Circuit Court of Appeals ruling that the Textron’s “tax-accrual work papers” are privileged material but that a lower court should reconsider whether the IRS can force Textron to turn over documents prepared by the company’s independent auditors. According to Kenworthy, the IRS has increasingly sought companies’ internal documents to fight a surge of corporate tax-shelter activity in the early part of the decade.