Argyle Sys. v. IRS (D.D.C.) -- concluding that IRS properly invoked Exemption 3 in conjunction with 26 U.S.C. § 6103(a) to categorically withhold various records, including Reporting Agent Authorization forms (i.e., Forms 8655); further concluding that statute’s foreseeable harm provision does not apply to Exemption 3 withholdings.

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