Case Description Cause of Action Institute submitted two FOIA requests to the IRS for records pertaining to communications and transmittals from the IRS to the Congress' Joint Committee on Taxation. Cause of Action Institute requested the documents after the Chief Counsel of the IRS issued guidance that such records should be considered congressional records, not agency records subject to FOIA. The agency denied Cause of Action Institute's requests based on its determination that such records were not agency records. Cause of Action Institute filed an administrative appeal and the agency upheld its initial decision. Cause of Action Institute then filed suit.