Leonard v. IRS, No. 13-4238, 2014 WL 5861580 (3d Cir. Nov. 13, 2014) (per curiam)

Leonard v. IRS, No. 13-4238, 2014 WL 5861580 (3d Cir. Nov. 13, 2014) (per curiam)

Re: Request for certain records filed with IRS bearing plaintiff's name

Disposition: Affirming the district court's grant of defendant's motion for summary judgment

• Exemption 3:  "After reviewing the record, [the Court of Appeals for the Third Circuit] conclude[s] that the IRS provided the District Court with sufficient factual basis for its determination that the small amount of information that was withheld from [plaintiff] fell within Exemption 3."  The Third Circuit relates that in this case, defendant relied on "Section 6103(a) [which] states, in pertinent part, that '[r]eturns and return information shall be confidential' and shall not be disclosed except as authorized by this title."  The Third Circuit finds that the records provided to plaintiff "were redacted only to the extent that they contained taxpayer identification numbers of third-party taxpayers."  Additionally, "[plaintiff] did not dispute the IRS's factual assertion that the redacted information consisted only of third-party taxpayer information."  "Nor did he allege or present any evidence showing that the third parties had consented to having their taxpayer identification numbers disclosed to him."