U.S. Appeals Court Upholds Disclosure of Return Information Under Transactional Relationship Exception

The U.S. Court of Appeals for the 9th Circuit held that a corporation’s return information was properly subject to disclosure in tax proceedings because it fell within the transactional relationship exception to confidentiality requirements, affirming the tax court’s denial of motions to seal. Appellant, a corporation that served as an intermediary in property sales, sought to seal documents containing its return information in two separate tax proceedings where it was not a party. The tax court denied the motions to seal, finding that although the material was generally entitled to confidentiality under IRC §6103, it fell within the exception for ...