Life Extension Found., Inc. v. IRS, No. 13-5053, 2014 U.S. App. LEXIS 4357 (D.C. Cir. Mar. 7, 2014) (per curiam)

Life Extension Found., Inc. v. IRS, No. 13-5053, 2014 U.S. App. LEXIS 4357 (D.C. Cir. Mar. 7, 2014) (per curiam)

Re: Request for records concerning audit of plaintiff conducted by Tax Exempt and Government Entities Examination Division

Disposition: Affirming district court's grant of defendant's motion for summary judgment and denial of plaintiff's cross-motion for summary judgment

• Exemption 1, Standard of Review: The court holds that "[t]here is no indication that the court applied a more deferential standard of review than is appropriate for all FOIA cases."  The court notes that there is a "difference between the standard of review in national security FOIA cases and the standard of review in plain vanilla FOIA cases."  However, the court finds that while "[t]he district court indeed cited a number of these national security cases in its discussion, . . . it did so in support of more broadly applicable points, and not to suggest that the IRS was entitled to special deference."

• Litigation Considerations, In Camera Inspection: The D.C. Circuit rejects appellant's argument "that the district court erred in failing to review the disputed documents in camera to determine if any segregable material was being withheld."  The court explains that "[t]hough the IRS affidavits in this case may not have been exemplars of detailed description, we do not believe that the district court abused its discretion in finding that the affidavits sufficiently described the material withheld."