Of course, given the highly personal information contained
in an individual's tax returns, and consistent with the very
confidentiality considerations embodied in § 6103, the privacy
protections afforded under FOIA Exemptions 6 and 7(C) should in
almost all cases provide a sufficient justification to withhold
such records from third-party requesters. Cf. Oklahoma
Publishing Co. v. HUD, Civil No. 87-1935, slip op. at 3-4 (W.D.
Okla. June 17, 1988) (credit "and other personal financial
information" protected under Exemption 6).
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