What guidance should be given to district courts that must decide whether the recipient of an IRS summons has raised a sufficient question about the government’s “improper purpose” to merit an evidentiary hearing?  The Eleventh Circuit’s per curiam decision in United States v. Clarke included a broad statement that the lack of an evidentiary hearing … Continue reading Argument analysis: What is the boundary on district court discretion to decide whether to develop evidence before enforcing an IRS summons?