Discovery of Tax Accrual Workpapers after Textron and Deloitte

Practical Tax Strategies, Feb 2011

9 Pages Posted: 10 Mar 2014

Date Written: February 9, 2011


The recent decisions of Textron and Deloitte have changed the landscape of tax practice by providing new guidance as to whether tax accrual workpapers are protected from discovery by the work product doctrine. However, the conflicting results of the Textron and Deloitte holdings as well as the inconsistency among other courts add uncertainty to the law surrounding the discovery of tax accrual workpapers making it an area prone for future litigation. A thorough understanding of the Arthur Young, Textron, and Deloitte decisions will empower counsel on either side of the representation with knowledge of how to argue for or against discovery of tax accrual workpapers.

Keywords: Tax, Work Product Doctrine, Textron, Discovery of Tax Workpapers.

Suggested Citation

Lipin, Ilya A., Discovery of Tax Accrual Workpapers after Textron and Deloitte (February 9, 2011). Practical Tax Strategies, Feb 2011, Available at SSRN:

Ilya A. Lipin (Contact Author)

PriceWaterhouseCoopers LLP ( email )

1301 Avenue of the Americas
New York, NY 10019
United States

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