1. If Glomar Responses are permitted should they be limited to instances involving national security, public safety, or public health?

2. Under what circumstances should a Federal Agency be denied use of a Glomar Response in litigation under FOIA and instead be required to provide a Vaughn Index and litigate the actual merits of the FOIA exemption it asserts as applicable?

3. Under what circumstances is it an abuse of a District Court's discretion to uphold the use of a Glomar Response instead of utilizing protective orders under Fed. R. Civ. P. 26(c) and in camera inspections under 5 U.S.C. §552(a)(4)(B) in conjunction with, or in addition to, a Vaughn Index to perform its de novo review of any documents or information sought under FOIA and claimed to be exempt by the Federal Agency?

Whether the Treasury Inspector General for Tax Administration can invoke the 'Glomar Response' to deny a FOIA request, and under what circumstances the use of the Glomar Response should be limited or denied in favor of other FOIA procedures