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Leonard v. Dep't of the Treasury, No. 10-6625, 2013 WL 4517912 (D.N.J. Aug. 26, 2013) (Kugler, J.)

Monday, August 26, 2013
Re: Taxpayer Identification Numbers of Third Parties Disposition: Granting defendant's motion for summary judgment
  • Exemption 3:  The court holds that defendant correctly invoked Exemption 3.  The court finds that, "[i]t is undisputed that Internal Revenue Code section 6103 is [] a qualifying statute."  The court explains that, "[t]his Code provision prohibits the disclosure of 'third-party tax return information without the authorization of the third party.'"  The court continues to state that, "'[r]eturn information' in turn is defined broadly, and refers to, among other things, 'a taxpayer's identity.'"  The court concludes by stating that, "the definition of the term 'taxpayer identity' includes a person's 'taxpayer identifying number,'" the information at issue here.
District Court
Exemption 3
Updated August 6, 2014