Alan Horowitz was quoted regarding the United States v. Clarke case in a summary of federal tax cases to watch in 2016. "The case raises important questions about the [Internal Revenue Service's (IRS's)] ability to use its summons power to aid in Tax Court litigation that were not addressed by the Supreme Court and will now be considered by the Eleventh Circuit on remand," Horowitz said. "If the summoned parties are able to successfully challenge the summonses on these grounds, that's going to be a concern to the IRS going forward."