Skip to Main Content

LAW360 Quotes Mark Allison: High Court Could Dim IRS Summons Power

June 11, 2014, Law360

Law360 quoted Mark D. Allison regarding the implications involved in United v. Clarke, et al. should the high court rule in the taxpayers' favor and reduce the IRS's summons power. Currently, the standard of proof required for an IRS summons is incredibly low, but a decision by the high court could require the government to provide more proof. With so much at stake, tax attorneys across the country are waiting to see which side the high court will take. For the complete article, please visit Law360's website (subscription required).

Excerpt taken from the article.

"If the taxpayer wins in this case, it could be a pretty major setback for the government," Mark D. Allison, member and tax attorney with Caplin & Drysdale Chtd.'s New York office, told Law360. "A taxpayer win might expose the IRS to a much more rigorous process for issuing summonses, and depending on the ruling, the government may not be able to rely on just a declaration of good faith anymore."


About Caplin & Drysdale
Celebrating our 55th Anniversary in 2019, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
New York, NY Office:
295 Madison Avenue
12th Floor
New York, NY 10017


This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
©2021 Caplin & Drysdale, Chartered
All Rights Reserved.