MEMORANDUM OPINION
HUVELLE, District Judge.
Plaintiff Tax Analysts filed this action under Internal Revenue Code § 6110, 26 U.S.C. § 6110, and the Freedom of Information Act, 5 U.S.C. § 552 ("FOIA"), seeking disclosure of numerous documents withheld by the Internal Revenue Service ("IRS"). Before the Court are two issues: first, whether written advice rendered to regional employees by attorneys in the IRS Office of Chief Counsel's national...
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