Fogg v. IRS (8th Cir.) -- following in camera inspection, affirming district court’s decision that agency properly relied on Exemption 7(E) to withhold portions of section 21.1.3.3 of the Internal Revenue Manual, because the contents concerning third-party authentication are “techniques and procedures for law enforcement investigations and their disclosure could reasonably be expected to risk circumvention of the law”; further concluding that the agency met the heightened foreseeable harm standard, which the district court neglected to address.
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