In May 2015, a district court in California ruled that the IRS could not obtain a corporate taxpayer’s records related to tax advice prepared by the taxpayer’s in-house tax lawyers. United States v. Sanmina Corp., No. 5:15-cv-00092 (2015 U.S. Dist. LEXIS 66123). The court held that the records were protected by the attorney-client confidentiality rules and that the IRS had not shown that the taxpayer had waived the attorney-client privilege. The court stated “the memoranda constituted tax advice from lawyers to Sanmina—not merely preparation of tax returns or number crunching…Both memos contain legal analysis, were prepared by Sanmina’s tax department lawyers, and were provided confidentially to company personnel who had a need for legal advice.” The tax advice was related to the tax implications of liquidation of a related corporate entity and contained lengthy legal analysis which were specifically prepared the contemplated transaction.