I previously blogged the Government's brief in opposition to Textron's certiorari petition in the U.S. Supreme Court (No. 09-750), which is seeking review of the First Circuit's 3-2 en banc decision in United States v. Textron, Inc., No. 07-2631 (1st Cir. Aug. 13, 2009), which reversed the 2-1 panel decision and held that Textron's tax accrual work papers were not protected under the work product doctrine and thus had to be turned over to the IRS in its tax shelter investigation. Elena Kagan, as Solicitor General, signed the brief:




