· 9/20/2023
In re M.W.-1 and C.W.
How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- noting that the IRS's \layers of review provide the taxpayer with substantial protection against the hasty or overzealous judgment of the special agent\
- noting that the IRS’s “layers of review provide the taxpayer with substantial protection against the hasty or overzealous judgment of the special agent”
- explaining that while an IRS “special agent is an important actor in the process, his motivation is hardly dispositive” when, the “review process over and above his conclusions is multilayered and thorough[ ]”
- noting the discussion by several circuit courts of the factual and legal issues involved in enforcement proceedings but declining to resolve the standard of review question
- noting the discussion by several circuit courts of the factual and legal issues involved in enforcement proceedings but declining to resolve the standard of review question
- adding requirement that government must show at time summons issued that matter had not been referred for criminal prosecution
Source: CourtListener parenthetical corpus (CC0).
Sourced from CourtListener / Free Law Project (CC0).
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