Robin Greenhouse commented for Tax Analysts (August 14) on the First Circuit's en banc U.S. v. Textron ruling, which reversed an earlier panel decision and held 3-2 that tax accrual workpapers are not subject to work product protection. She said the majority's new work product rule "is directly in conflict with the Second Circuit's decision in Adlman and is even more restrictive than the Fifth Circuit's 'primary motivating purpose' standard." She noted that the dissent would support a petition for certiorari by Textron: "There are significant nontax ramifications from this decision, and all litigators and general counsel should be concerned. This decision opens the door for one part in litigation to discover an opposing party's litigation reserve fund." She made similar points for Bloomberg.com, where she observed that the ruling was "a very results-oriented decision. The court wanted to find that this was not privileged."