Kevin Kenworthy discusses the decision handed down by the First Circuit Court of Appeals, allowing the IRS to access work papers documenting Textron’s tax and litigation risks. Kenworthy warns that Textron has implications well beyond tax work papers, a fact even noted in the court’s dissenting opinion. Liabilities of any kind—tax, environmental, tort, product liability—use the same sort of analysis to evaluate litigation hazards, he explains. “There would be others on the other side of litigation who would very much like to have that information. In principle, I don’t see how this decision can be limited to tax reserves.”