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7 canonical passages across 5 cases, quoted by 218 opinions in total. These passages cluster together because the same opinions keep quoting them side by side: they state parts of one doctrine. The anchor passage is from United States v. Powell.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | United States v. Powell Anchor | green | “must show that the investigation will be conducted pursuant to a legitimate purpose, that the inquiry may be relevant to the purpose, that the information sought is not already within the commissioner's possession, and that the administrative steps required by the code have been…” | 105 |
| 2 | United States v. Powell | green | “such an abuse would take place if the summons had been issued for an improper purpose, such as to harass the taxpayer or to put pressure on him to settle a collateral dispute, or for any other purpose reflecting on the good faith of the particular investigation.” | 59 |
| 3 | United States v. Powell | green | “it is the court's process which is invoked to enforce the administrative summons and a court may not permit its process to be abused.” | 21 |
| 4 | United States v. Euge | green | “has consistently construed congressional intent to require that if the summons authority claimed is necessary for the effective performance of congressionally imposed responsibilities to enforce the tax code, that authority should be upheld absent express statutory prohibition o…” | 13 |
| 5 | United States v. Arthur Young & Co. | green | “expansive information-gathering authority” | 12 |
| 6 | United States of America and Dennis J. Hanzel, Special Agent, Internal Revenue Service v. Jay T. Will | green | “the requisite showing is generally made by the submission of the affidavit of the agent who issued the summons and who is seeking enforcement.” | 5 |
| 7 | United States v. Judicial Watch, Inc. | green | “that the records sought are extensive is not material so long as the records are relevant to the matters at issue in the audit.” | 3 |
A red or yellow flag on a member means the underlying case has negative treatment: for those, check the case page before relying on the passage.