The I.R.S. requested an oral history tape from the the county historical
society I directed. Our lawyer told us to turn the item over to them.  The
subject matter had to do with  projected use of land by a local family.
When I was a curator, the I.R.S. demanded my notes relative to the value
of a collection of antique and special interest automobiles donated to the
museum where I worked.
  I guess if an institution had the funds they could contest an order
based on the same grounds a journalist might use.  There is probably some
case law relative to the Nixon tapes and the National archives.