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U.S. v. CLARKE

No. 13-301.

134 S.Ct. 2361 (2014)

189 L.Ed.2d 330

UNITED STATES, Petitioner v. Michael CLARKE et al.

Supreme Court of United States.

Decided June 19, 2014.

Attorney(s) appearing for the Case

Sarah E. Harrington, for Petitioner.

Edward A. Marod, West Palm Beach, FL, for Respondents.

Edward A. Marod, Counsel of Record, Jack J. Aiello, Martin R. Press, Gunster, Yoakley & Stewart, P.A., West Palm Beach, FL, Seth P. Waxman, Paul R.Q. Wolfson, Joshua M. Salzman, Christina Manfredi McKinley, Wilmer Cutler Pickering Hale and Dorr LLP, Washington, DC, Carleen M. Zubrzycki, Wilmer Cutler Pickering Hale and Dorr LLP, New York, NY, for Respondents.

Donald B. Verrilli, Jr., Solicitor General, Counsel of Record, Kathryn Keneally, Assistant Attorney General, Malcolm L. Stewart, Deputy Solicitor General, Sarah E. Harrington, Assistant to the Solicitor General, Robert W. Metzler, Deborah K. Snyder, Attorneys, Department of Justice, Washington, DC, for Petitioner.

Justice KAGAN delivered the opinion of the Court.

The Internal Revenue Service (IRS or Service) has broad statutory authority to summon a taxpayer to produce documents or give testimony relevant to determining tax liability. If the taxpayer fails to comply, the IRS may petition a federal district court to enforce the summons. In an enforcement proceeding, the IRS must show that it issued the summons in good faith.

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