Levitt v. IRS (N.D. Ala.) -- deciding that: (1) IRS reasonably interpreted plaintiff’s request for “any and all correspondence related to the FPA [Final Partnership Adjustment] sent to both the Taxpayer and PR [Partnership Representative]” as seeking only correspondence actually sent to both parties; rejecting plaintiff’s argument that the phrase “sent to both the Taxpayer and PR” was merely a descriptor for the FPA itself, reasoning that plaintiff had already defined the term “FPA” earlier in the request; further noting that plaintiff could simply submit a new request if he wanted internal agency correspondence about the FPA; and (2) the fact that agency’s FOIA production did not include any records “that tend to prove or disprove that the Taxpayer or PR received the FPA,” as plaintiff requested, did not undermine the adequacy of IRS’s search.
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