379 U.S. 48 (1964) Cited 1,916 times 20 Legal Analyses
Holding that the government needs to show probable cause only when the taxpayer raises a substantial question that judicial enforcement constitutes an abuse of process
Holding that it was proper for the district court to consider, on a motion to dismiss under Fed. R. Civ. P. 12(b), exhibits attached to the Complaint, materials referenced in the Complaint, and all materials in the state court's file
Holding that a district court lacks jurisdiction to consider petitions to quash summonses issued to entities not residing or "found" in the court's geographical jurisdiction
469 U.S. 310 (1985) Cited 109 times 2 Legal Analyses
Holding that the assertion that the IRS is seeking information relating to audits of other taxpayers, even if true, does not render a summons illegitimate if there is another legitimate purpose of its issuance
In Alphin v. United States, 809 F.2d 236 (4th Cir. 1987), we discussed generally the standards which govern analysis of whether the government has satisfied its obligations under Powell and, in more specific terms, the procedures which district courts should follow in summons enforcement proceedings.