I KNOW IT WHEN I SEE IT: TEXTRON, TAX-ACCRUAL PAPERS, THE SHRINKING WORK-PRODUCT PRIVILEGE, BLACK POWDER, SWEAT, AND BLOOD.

The article focuses on concerns regarding work-product privilege originated in the U.S. Supreme Court case, Hickman v. Taylor and its application to tax-accrual papers. In United States v. Textron Inc., the U.S. Court of Appeals for the First Circuit held that the work-product privilege does not protect tax-accrual papers from Internal Revenue Service (IRS) discovery. It also examines various policies in relation to the application of product privilege to tax-accrual papers.