LAW360 Quotes Mark Allison: High Court Could Dim IRS Summons Power
Law360 quoted Mark D. Allison regarding the implications involved in United v. Clarke, et al. should the high court rule in the taxpayers' favor and reduce the IRS's summons power. Currently, the standard of proof required for an IRS summons is incredibly low, but a decision by the high court could require the government to provide more proof. With so much at stake, tax attorneys across the country are waiting to see which side the high court will take. For the complete article, please visit Law360's website (subscription required).
Excerpt taken from the article.
"If the taxpayer wins in this case, it could be a pretty major setback for the government," Mark D. Allison, member and tax attorney with Caplin & Drysdale Chtd.'s New York office, told Law360. "A taxpayer win might expose the IRS to a much more rigorous process for issuing summonses, and depending on the ruling, the government may not be able to rely on just a declaration of good faith anymore."