Smart-Tek Serv. Solutions Corp. v. IRS (S.D. Cal.) -- determining that: (1) IRS performed adequate search for plaintiff’s administrative files; (2) IRS properly withheld return information of plaintiff’s corporate alter ego pursuant to Exemption 3, in conjunction with 26 U.S.C. § 6103(a); and (3) IRS properly withheld third-party information pursuant to Exemption 6 and plaintiff’s “risk score” pursuant to Exemption 7(E).
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