As we described in our January 28, 2009, Client Update, a majority of a three-judge panel of the Court of Appeals for the First Circuit held that the work product doctrine could protect the schedules and supporting documentation behind a company’s reserve for contingent tax liabilities, known as “tax accrual workpapers,” from IRS discovery. U.S. v. Textron, Inc., 553 F.3d 87 (1st Cir. 2009) (the “panel majority opinion”).