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5 canonical passages across 4 cases, quoted by 40 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 | “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.” | 16 |
| 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.” | 13 |
| 3 | Reisman v. Caplin | green | “challenge the summons on any appropriate ground.” | 5 |
| 4 | 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 |
| 5 | Jules Samann v. Commissioner of Internal Revenue | green | “would be contrary to any treaty obligation of the united states in effect on the date of enactment of this title.” | 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.