What is the current state of the law on disclosure of personal information under the Privacy Protection Act?

The majority is absolutely correct that the government's interest in maintaining a workable tax system is "compelling." See Bradley v. United States, 817 F.2d 1400, 1405 (9th Cir.1987). ¹³ Confidentiality of tax return information is a critical component of a tax system based on self-reporting of income. See United States v. Bisceglia, 420 U.S. 141, 145, 95 S.Ct. 915, 918, 43 L.Ed .2d 88 (1975). But this only serves to establish the validity of the statute in general. It does not tell us when an exception is or is not warranted in order to preserve constitutional principles. Here, we are faced with a specific factual situation and asked to make an extremely narrow exception to the statute. There is no reason to think that the narrow exception Richey seeks would jeopardize the entire tax system or result in wholesale disclosure of citizens' tax returns. While we must remain aware of the importance of the government's general interest in nondisclosure and proceed cautiously, where countervailing first amendment interests exist the Constitution obligates us to look carefully at the particular harm to the individual involved as well as the general harm to first amendment values that would result from suppression of the specific speech at issue.