Tax Analysts v. Internal Revenue Service
CourtDistrict Court, District of Columbia
Date FiledSeptember 9, 2026
DocketCivil Action No. 2024-3257
JudgeJudge Paul L. Friedman
StatusPublished
📰 News Coverage: Read the LAWS.com news report on this case
Full Opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
TAX ANALYSTS,
Plaintiff,
Civil Action No. 24-3257 (PLF)
Vv.
INTERNAL REVENUE SERVICE,
Defendant.
ee Nee Ne ee ee ee ee ee ee
MEMORANDUM OPINION AND ORDER
This matter is before the Court on the motion of the Internal Revenue Service
CIRS”) for summary judgment [Dkt. No. 29] and the plaintiff's response to that motion (“PI.
Resp.”) [Dkt. No. 30]. After the filing of several joint status reports and requests for extensions
of time, the IRS filed its reply in support of its motion for summary judgment (“Reply”) [Dkt.
No. 31] on August 26, 2026.
The parties have agreed that this case can easily be resolved once the identity of
the subject taxpayer is known. See Pl. Resp. at 1; Reply at 1. Plaintiff does not have this
information and, for reasons to be explained, the IRS refuses to make it available to the plaintiff.
Instead, the parties agree that the case could move forward if this Court reviewed the disputed
material in camera. See Pl. Resp. at 2; Reply at 1-2. At the Court’s request, the IRS delivered
the relevant materials to the Court on September 4, 2026, and the Court has now reviewed them.
The parties agree that former IRS contractor Charles Littlejohn publicly disclosed
tax return information of “some prominent Americans,” including Donald Trump, Warren
Buffett, Bill Gates, Rupert Murdoch, Mark Zuckerberg, Jeff Bezos, Elon Musk, and others. The
parties now also agree that if the taxpayer here is a person of such prominence, he or she could
easily be identified with the Littlejohn disclosure and related news reporting. See Pl. Resp. at 2;
Reply at 1-2. Any member of the public would be able to identify the subject taxpayer. If that
is the case, the parties agree, the Court necessarily would conclude that the withheld documents
are exempt from disclosure. See id. (citing 26 U.S.C. § 6110(c)(1) and (c)(5)). The Court,
having now reviewed the documents in camera, concludes that the subject is a person of such
prominence that disclosure would be tantamount to identifying the taxpayer. Therefore, the
records may be withheld. Accordingly, it is hereby
ORDERED that on or before September 23, 2026, the parties shall meet and
confer and file a joint status report suggesting appropriate next steps in this case.
PAUL L. FRIEDMAN
United States District Judge
SO ORDERED.