Pacific Fisheries, Inc. v. Internal Revenue Service

2 Citing cases

  1. Lowy v. Internal Revenue Service

    C 10-00767 SI (N.D. Cal. Mar. 30, 2011)

    This definition has been held to include two categories of information: (1) information received by the IRS from a foreign tax administration; and (2) information sent by the IRS to a foreign tax administration provided that the information "relates to and/or reflects on" information it received from the foreign tax administration. See Pacific Fisheries, Inc. v. Internal Revenue Service, No. C04-2436JLR, 2009 WL 1249296, at *4 (W.D. Wash. May 6, 2009), aff'd sub nom. Pacific Fisheries, Inc. v. United States, 395 F.Appx. 438 (9th Cir. 2010).

  2. Shannahan v. Internal Revenue Service

    680 F. Supp. 2d 1270 (W.D. Wash. 2010)   Cited 7 times

    A district court reviews de novo the IRS's determination that the release of withheld documents would seriously impair federal tax administration. Long v. U.S. Internal Revenue Serv., 742 F.2d 1173, 1182-83 (9th Cir. 1984); Pac. Fisheries, Inc. v. Internal Revenue Serv., No. C04-2436JLR, 2009 WL 1249296, at *3 (W.D.Wash. May 6, 2009). The IRS bears the burden on this issue.