Replaying the victory of Textron[1] in 2007, Regions Financial Corporation (“RFC”) prevailed on May 8, 2008 in its opposition to an IRS summons seeking certain tax accrual workpapers from RFC’s outside auditor. While the IRS has been successful litigating the merits of what it considers to be abusive shelters, it has largely met with failure in attempting to override evidentiary protections

such as the work product doctrine.

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