Andrew Strelka Quoted on Summons Evidentiary Hearings in Tax Notes Today

"ABA Meeting: Summons Evidentiary Hearing a Two-Way Street, DOJ Official Warns"
Tax Notes Today
02.02.15Andrew Strelka was quoted regarding the role of the Clarke decision on a taxpayer's ability to get an evidentiary hearing to prove that an IRS summons was issued for an improper purpose. "Since the Supreme Court's opinion, there have been multiple courts around the country that have cited Clarke in enforcement proceedings and in not one of those cases was an evidentiary hearing granted," continuing with the historical trend of a rarity of those hearings, Strelka said. But he added that "some of those opinions are going up on appeal, so there is still the possibility that this could continue to evolve."
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