George Hani is quoted regarding the IRS’ increased use of the administrative summons to obtain sensitive documents from taxpayers. “Agents are much more frequently throwing out the 'summons' word early in the process," Hani said. "Any transaction that is perceived to be abusive or big-dollar, you are more likely to hear someone say 'summons.'" There were 132 summons-related legal disputes in 2011, up from 44 in 2005, but many taxpayers are challenging the orders. According to the Taxpayer Advocate Service, a government watchdog that oversees the IRS, this was the most litigated issue that the agency faced last year.