Case: Agent’s Declaration Overrides Need for Vaughn Index in FOIA Request (S.D. Fla.)

April 29, 2020, 5:00 AM UTC

Motion to compel Vaughn index in FOIA case denied where IRS’s response by declaration of revenue agent sufficient to provide information leading to exemption reasoning, a district court held. Taxpayer in his FOIA request seeks information regarding personnel records of IRS employees working on his private letter rulings. A Vaughn index is “a detailed index showing justification for withholding each document.” The court noted that the agent’s declaration provides similar information that the creation of a Vaughn index is not needed. The court did grant Taxpayer an extension of time to respond to the government’s motion for summary judgment. [ ...

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