Lowy et al v. Internal Revenue Service

Filing 67

ORDER MODIFYING MARCH 30, 2011 ORDER (Illston, Susan) (Filed on 11/28/2011)

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1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE NORTHERN DISTRICT OF CALIFORNIA 7 8 PETER LOWY, et al., 9 United States District Court For the Northern District of California 10 11 12 No. C 10-00767 SI Plaintiffs, ORDER MODIFYING MARCH 30, 2011 ORDER v. INTERNAL REVENUE SERVICE, Defendant. / 13 14 The Court has reviewed the parties’ briefing on defendant’s motion to modify or vacate this 15 Court’s March 30, 2011 Order. The Court finds that its March 30, 2011 Order should be amended to 16 correct an oversight and MODIFIES that Order, at page 15 lines 8-11, as follows: “Withholding these 17 documents under section 6105 is improper unless the IRS can show that they contain information 18 relating to and/or reflecting information received from the foreign tax administration.” 19 20 IT IS SO ORDERED. 21 22 23 24 25 26 27 28 Dated: November 28, 2011 SUSAN ILLSTON United States District Judge

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