United States v. Clarke

Summary

The Court held that a taxpayer may examine IRS officials about a summons only when he points to specific facts or circumstances that plausibly infer bad‑faith, rejecting the Eleventh Circuit’s categorical rule; it affirmed that appellate review of a district court’s decision on this issue is abuse‑of‑discretion deference limited to correct legal standards, and vacated and remanded the case for further proceedings.