The Supreme Court on June 19 unanimously vacated and remanded an Eleventh Circuit per curiam decision in United States v. Clarke.  The Eleventh Circuit had reversed a district court refusal to grant a summons recipient an evidentiary hearing to challenge an IRS summons.  The Supreme Court emphasized the abuse of discretion standard applicable to the … Continue reading Opinion analysis: Court clarifies standard for evidentiary hearing in enforcement of IRS summons