Tax Analyst et al., v. District of Columbia 2020 CA 001999 B July 1, 2024 District of Columbia’s Amended Vaughn Index Document Information Statutory Reasons Withheld Name Redacted Basis 1-28-2016 There are a total of six D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling pages and page four 534(a)(2), (6); 47- specific information such as the taxpayer’s name, address, on Sales and Use was released in full. 4406; 47-2018; 47- telephone number, and business name. The Conclusion and Tax 1805.04 Facts were redacted in its entirety because the sections included Pages 1–3 and 5–6 factual descriptions of the taxpayer’s business, the purpose of were redacted in part. the taxpayer’s business, and the taxpayer’s service that is subject to the sales and use tax. All this information was received from the taxpayer or prepared by the Office of Tax Revenue (OTR), to determine the existence of potential tax liability and includes OTR’s discussion of the tax treatment of the taxpayer’s specific facts. The name of the taxpayer was redacted in the Issue Section and the Analysis section was redacted in part because it included a discussion of the application of the law to the specific taxpayer business facts for the purpose of determining the existence or potential existence of the taxpayer’s tax liability. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of the redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47-2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. Tax Analyst et al., v. District of Columbia 2020 CA 001999 B 2-3-2016 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer specific Private Letter Ruling three pages, which 534(a)(2), (6); information such as the taxpayer’s name, address, and product on Sales and Use Tax were redacted in part. 47-4406; 47-2018; name. The Issue, Conclusion, Facts, and Summary sections 47-1805.04 were redacted in their entirety because it included the taxpayer name, the taxpayer’s business product, a description of how the product functions, and OTR’s discussion of the tax treatment of the taxpayer’s specific facts. The Analysis section was redacted in part because it includes factual descriptions of the taxpayer business product that was supplied to OTR, or prepared by OTR, to determine the existence of potential tax liability and include OTR’s taxpayer specific legal analysis. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. Tax Analyst et al., v. District of Columbia 2020 CA 001999 B 2-11-2016 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter four pages which 534(a)(2), (6); 47- specific information such as the taxpayer’s name and address. Ruling on QHTC were redacted in part. 4406; 47-2018; 47- The Facts section was redacted in its entirety because it Tax 1805.04 describes the taxpayer’s business, how the taxpayer generated income, and the services the taxpayer provided. The Issue section was redacted in part because it contained factual scenarios regarding the taxpayer’s specific business and services rendered. The Law & Analysis sections were redacted in part because they include factual descriptions of the taxpayer business and its services that were supplied to OTR by the taxpayer or prepared by OTR to determine the existence of potential tax liability and OTR’s discussion of the tax treatment of the taxpayer’s specific facts The portion redacted was OTR’s discussion of the tax treatment of the taxpayer’s business and service. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. Tax Analyst et al., v. District of Columbia 2020 CA 001999 B 2-19-2016 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter three pages which 534(a)(2), (6); 47- specific information such as the taxpayer’s name and address. Ruling on were redacted in part. 4406; 47-2018; 47- The Issue and Facts was redacted in its entirety because it Franchise Tax 1805.04 describes the taxpayer, and its services, and it contains a table that summarizes the specific tax treatment it received, and benefits claimed by the taxpayer. The Issue section specifically was redacted because it references specific facts about the taxpayer, and once the taxpayer specific information was removed, no meaningful information remained. The Law & Analysis sections were redacted partly because they include factual descriptions of the taxpayer’s business and its services and OTR’s discussion of the tax treatment of the taxpayer’s specific facts and business. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. Tax Analyst et al., v. District of Columbia 2020 CA 001999 B 2-25-2016 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains tax-payer- Private Letter Ruling five pages which 534(a)(1), (2), (6). specific information such as the taxpayer’s name and address. on Sales and Use Tax were redacted in part. D.C. Code §§ 47- The Facts and Ruling Requested sections were redacted in its 4406; 47-2018; 47- entirety because it described the taxpayer’s business, the 1805.04 locations of the taxpayer’s business, and the taxpayer’s business operations. The Law & Analysis, and Conclusion sections were redacted in part because it included the factual descriptions of the taxpayer’s business and services, a request for taxpayer specific documents to assist OTR in its analysis of the tax treatment of the taxpayer’s activities, and OTR’s discussion of the tax treatment of the taxpayer’s specific facts. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. Tax Analyst et al., v. District of Columbia 2020 CA 001999 B 11-3-2016 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling six pages which were 534(a)(2), (6); 47- specific information such as the taxpayer’s name and address. on Franchise Tax redacted in part. 4406; 47-2018; 47- The Issue and Facts section was redacted in its entirety 1805.04 because it includes factual descriptions of the taxpayer’s business and services that were supplied to OTR, or data prepared by OTR to determine the existence of potential tax liability. The Conclusion and Analysis section was partly redacted to remove materials that were specific to the taxpayer’s business and services and OTR’s discussion of the tax treatment of the taxpayer’s specific facts. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. 1-26-2017 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling five pages. Page three 534(a)(2), (6); 47- specific information such as the taxpayer’s name and address. on Sales Tax was released in full. 4406; 47-2018; 47- The Issues and Taxpayer Business Activities were redacted in 1805.04 its entirety because it included the factual descriptions of the Pages 1–2 and 4–5 taxpayer’s business and services that were supplied to OTR, were redacted in part. Issue 3 of the Legal Analysis section was redacted to protect OTR’s discussion of the tax treatment of the taxpayer’s specific facts. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of Tax Analyst et al., v. District of Columbia 2020 CA 001999 B personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. 2-23-2017 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling three pages, and page 534(a)(2), (6); 47- specific information such as the taxpayer’s name and address. on Sales and Use Tax two was released in 4406; 47-2018; 47- The Facts section is redacted in its entirety because it describes full. 1805.04 the taxpayer’s business. Pages one and three The Issue, Law & Analysis, and Conclusion sections were were redacted in part. redacted partly because it contained facts and OTR’s discussion of the tax treatment of the products and services the taxpayer provides. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portion of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. Tax Analyst et al., v. District of Columbia 2020 CA 001999 B 5-9-2017 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer- Private Letter Ruling three pages which 534(a)(2), (6); 47- specific information such as the taxpayer’s name and address. on Sales and Use Tax were redacted in part. 4406; 47-2018; 47- The Facts was redacted because the section discussed the 1805.04 taxpayer’s products and a chart of the taxpayer’s products. Other redacted portions of the ruling contain discussion of the tax treatment of the taxpayer’s specific facts Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. 7-5-2017 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer- Private Letter Ruling seven pages and page 534(a)(2), (6); 47- specific information such as the taxpayer's name and address. on QHTC Tax four was released in 4406; 47-2018; 47- The Facts section was redacted in its entirety because it full. Page two was 1805.04 described the taxpayer’s business, the taxpayer’s revenue redacted fully. structure, the taxpayer’s technology, and patent information. Pages 1, 3 and 5–7 The Issue, Law, Analysis, and Conclusion sections were were redacted in part. redacted in part because they included OTR’s discussion of the tax treatment of the taxpayer’s specific facts, including the taxpayer’s business and its eligibility to claim benefits as a QHTC. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted Tax Analyst et al., v. District of Columbia 2020 CA 001999 B portions is not reasonably segregable or disclosure would not yield meaningful information. 7-7-2017 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling three pages which 534(a)(2), (6); 47- specific information such as the taxpayer's name and address. on Sales and Use Tax were redacted in part. 4406; 47-2018; 47- 1805.04 The Issue and Facts section was redacted in its entirety because it included the taxpayer’s name, specific taxpayer facts, and described the taxpayer’s business activities The Law & Analysis sections were redacted in part because they included a discussion of the taxpayer’s business services and prepared by OTR to determine the existence of potential tax liability. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. Tax Analyst et al., v. District of Columbia 2020 CA 001999 B 9-1-2017 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling three pages which 534(a)(2), (6); 47- specific information such as the taxpayer’s name and address. on Sales and Use were redacted in part. 4406; 47-2018; 47- The Issue and Facts sections were redacted in its entirety Tax 1805.04 because it describes the taxpayer’s business, taxpayer’s address, taxpayer’s agreement with other entities, and the taxpayer’s employees. The Law & Argument, and Conclusion sections were redacted in part because they included factual descriptions of the taxpayer business and services that were supplied to OTR to determine the existence of potential tax liability and OTR’s discussion of the tax treatment of the taxpayer’s specific facts. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. 3-20-2018 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling four pages which are 534(a)(2), (6); 47- specific information such as the taxpayer's personally on Sales and Use Tax redacted in part. 4406; 47-2018; 47- identifiable information. The Issue and Facts sections were 1805.04 redacted in their entirety because they explained taxpayer’s services, the taxpayer’s products and the name of the taxpayer. The Law & Analysis sections were redacted in part because they included factual descriptions of the taxpayer services that were supplied to OTR, or prepared by OTR, to determine the existence of potential tax liability and OTR’s discussion of the tax treatment of the taxpayer’s specific facts. Tax Analyst et al., v. District of Columbia 2020 CA 001999 B Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. 5-10-2018 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling three pages which are 534(a)(2), (6); 47- specific information such as the taxpayer's personally on Sales and Use Tax redacted in part. 4406; 47-1805.04 identifiable information. The Issue and Facts were redacted in its entirety because it included facts about the taxpayer’s business service, its revenue structure, and business model. The Conclusion section was redacted in part because included OTR’s taxpayer-specific discussion of the tax treatment of the taxpayer’s services described in the prior sections. The portion was redacted because it included OTR’s discussion of the tax treatment of the taxpayer’s specific facts and analysis of any potential tax liability. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. Tax Analyst et al., v. District of Columbia 2020 CA 001999 B 6-28-2018 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling six pages, and page 534(a)(2), (6); 47- specific information such as the taxpayer's name and address. on QHTC Tax three was released in 4406; 47-2018; 47- The Facts were redacted in its entirety because it described the full. 1805.04. taxpayer’s business structure, the location of the taxpayer’s officer, the type of services the taxpayer offers, how the Pages 1–2 and 4–6 taxpayer’s business provides its service to its clients, and the were redacted in part. taxpayer’s revenue structure at the relevant time. The Issue, Law, Analysis, and Conclusion sections were redacted in part it includes the name of the taxpayer, OTR’s discussion of the tax treatment of the taxpayer’s specific facts and the taxpayer’s specific business structure, and OTR’s determination and justification as to whether the taxpayer meets the QHTC qualifications. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. Tax Analyst et al., v. District of Columbia 2020 CA 001999 B 8-2-2018 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling three pages which 534(a)(2), (6); 47- specific information such as the taxpayer's name and address. on Sales and Use Tax were partially 4406; 47-2018; 47- The Facts section was redacted in its entirety because it redacted. 1805.04. contains a factual description of the taxpayer’s business and the services it renders to customers. The Issue, Law & Argument, and Conclusion sections were redacted in part because they included factual descriptions of the taxpayer business and services that were supplied to OTR and OTR’s discussion of the tax treatment of the taxpayer’s specific facts and determination of whether taxpayer’s specific service is excluded from the sales and use tax. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. 10-12-2018 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling three pages which 534(a)(2), (6); 47- specific information such as the taxpayer's name, address, and on Individual Income were partially 4406; 47-2018; 47- personally identifiable information. The Facts was redacted in Tax redacted. 1805.04. its entirety because it included facts about personally identifiable information about the taxpayer. The Law & Analysis and Conclusion sections were redacted in part because they included OTR’s discussion of the tax treatment of the taxpayer’s specific facts and determination of whether the injured spouse protection applied specifically to the taxpayer. Tax Analyst et al., v. District of Columbia 2020 CA 001999 B Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. 12-7-2018 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling three pages which 534(a)(2), (6); 47- specific information such as the taxpayer's name and address. on Estate Tax were partially 4406; 47-2018; 47- redacted. 1805.04. The Facts was redacted in its entirety because it included facts about the decedent’s estate. The Law & Analysis and Conclusion sections were redacted in part because they included OTR’s discussion of the tax treatment of the taxpayer’s specific facts and determination whether the decedent’s estate is subject to taxation. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. Tax Analyst et al., v. District of Columbia 2020 CA 001999 B 2-14-2019 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling three pages which are 534(a)(2), (6); 47- specific information such as the taxpayer's name and address. on QHTC Tax redacted in part. 4406; 47-2018; 47- 1805.04. The Issue and Facts were redacted in its entirety because it included the taxpayer’s name, and a factual description of the taxpayer’s business services and products. The Law & Analysis and Conclusion sections were redacted in part because they included OTR’s discussion of the tax treatment of the taxpayer’s specific facts and business and whether the QHTC tax exemption applied. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. 2-21-2019 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling seven pages. Pages 534(a)(2), (6); 47- specific information such as the taxpayer’s name and address. on Sales and Use Tax 2–4 were redacted in 4406; 47-2018; 47- whole. The remaining 1805.04 The Issue, Facts and Conclusion sections were redacted in pages were redacted their entirety because they include factual descriptions of the in part. taxpayer’s membership structure, taxpayer’s revenue structure, and the taxpayer’s business services. The Facts section also included a summary of the taxpayer’s previous private letter ruling. The Law & Analysis section was redacted in part to exclude OTR’s discussion of the tax treatment of the taxpayer’s specific facts and its conclusions as to the taxpayer’s potential Tax Analyst et al., v. District of Columbia 2020 CA 001999 B tax liability. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. 2-28-2019 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling two pages which 534(a)(2), (6); 47- specific information such as the taxpayer’s name and address. on Franchise Tax were partially 4406; 47-2018; 47- redacted. 1805.04 The Issue and Facts were redacted in its entirety because it includes a factual description of the taxpayer’s business and transactions, and services and the taxpayer’s specific legal issue. The Law & Argument section was redacted in part because they included OTR’s discussion of the tax treatment of the taxpayer’s specific facts and activities for purposes of determining potential tax liability. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. Tax Analyst et al., v. District of Columbia 2020 CA 001999 B 4-12-2019 There are a total of 12 D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling pages and pages ten 534(a)(2), (6); 47- specific information such as the taxpayer’s name and address. on Sales and Use Tax and 11 were redacted 4406; 47-2018; 47- entirely. The 1805.04 The Issue, Facts, and Conclusion sections were redacted in its remaining pages were entirety because it included factual descriptions of the redacted in part. taxpayer’s business and services, the specific issues concerning the taxpayer, and the legal conclusion OTR determined based on the taxpayer specific information. The Analysis was redacted in part because it includes information about the taxpayer and OTR’s discussion of the tax treatment of the taxpayer’s specific facts. . Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. 7-11-2019 There are a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling four pages which 534(a)(2), (6); 47- specific information such as the taxpayer’s name and address. on Sales Tax were redacted in part. 4406; 47-2018; 47- The Issue and Facts sections were redacted in its entirety 1805.04 because it included factual descriptions of the taxpayer’s business and services. Although the section uses generic language, the Issues section contains information about the taxpayer’s business activities which should be protected. Information about contract terms and taxpayer activities should be redacted, which doesn’t allow reasonable segregation or yield meaningful information. The Application and Conclusions sections were redacted in Tax Analyst et al., v. District of Columbia 2020 CA 001999 B part because of OTR’s discussion of the tax treatment of the taxpayer’s specific facts and its business and services. The sections included information about the taxpayer’s business activities and even though the activities may be generic in nature the information is still specific to the taxpayer. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not yield meaningful information. 7-15-2019 There were a total of D.C. Code §§ 2- Content of Withholding: The record contains taxpayer Private Letter Ruling five pages and page 534(a)(2), (6); 47- specific information such as the taxpayer's name and address. on Sales Tax two was redacted in 4406; 47-2018;47- its entirety. The 1805.04 The Issue, Facts, and Conclusion sections were redacted in remaining pages were their entirety because they include a factual description of the redacted in part. taxpayer’s business and services provided. The Application section was redacted in part because it included OTR’s discussion of the tax treatment of the taxpayer’s specific facts and determination of whether the taxpayer’s services were subject to sales tax. Reason for Withholding: Disclosing personal information in this record would be a clearly unwarranted invasion of personal privacy and disclosure of redacted portions of this record is specifically prohibited by D.C. Code §§ 47-4406, 47- 2018, and 47-1805.04 protecting the confidentiality of tax and return information. Any nonexempt material in the redacted portions is not reasonably segregable or disclosure would not Tax Analyst et al., v. District of Columbia 2020 CA 001999 B yield meaningful information.