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.