The Court allowed the IRS to retain the results of its first search but ordered the agency to release additional records. The IRS had not properly explained why it withheld documents under FOIA, and was wrong to call most of Schiff’s second request too vague.
Holding
The district Court gave both sides a partial win. It found the IRS did a proper search for Schiff’s first FOIA request but did not justify withholding records under Exemptions 5, 7(A), and 7(E). The IRS must process most of Schiff’s second request, except for one broad part about unnamed foreign tax authorities.
Why It Matters
This decision is a significant FOIA setback for the IRS. While the agency succeeded on the search issue, it lost on the more important question of disclosure.
The opinion makes clear that generic explanations are insufficient to satisfy FOIA exemptions. Agencies have to explain why an exemption applies and how releasing the records would actually cause harm.
The Court draws a practical line on broad keywo…
