In a brief filed with the U.S. Supreme Court on March 17 and scheduled for a hearing April 23, Michael Clarke and his partners in Dynamo Holdings, LP argued that they are entitled to a limited evidentiary hearing to show that summonses were issued improperly by the IRS as retribution for their refusal to extend a statute of limitations.

The Eleventh Circuit earlier ruled in Clarke’s favor, and the IRS appealed to the Supreme Court.

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