investigation exception in the case before it, but was not presented with and did not specifically comment upon cases in which the disclosing party had entered into a confidentiality agreement. Permian Corp. v. United States, 665 F.2d 1214 (D.C.Cir.1981). Only one court of appeals has rejected the government investigation exception when the disclosing party had entered into some kind of confidentiality agreement with the government. Westinghouse Elec. Corp. v. Republic of the Philippines, 951 F.2d 1414, 1427-27 (3d Cir.1991). All of the other circuit decisions that the court cites either concern whether disclosures to one federal government agency waive privilege as to another federal government agency, United States v. Massachusetts Inst. of Tech., 129 F.3d 681, 686 (1st Cir.1997) (<HOLDING>), or address privileges other than the
holding that the irs has a law enforcement purpose in the context of a criminal tax investigation holding that the statute establishing the confidentiality of department of children youth and famines records did not create a testimonial privilege recognizing a corporations legal rights to confidentiality and privilege holding that disclosure to department of defense audit committee without a confidentiality agreement waived privilege in irs investigation holding that attorneyclient privilege was not waived when a letter sent by an irs regional counsel to the doj requesting legal services was copied to other irs personnel involved in the investigation