The Supreme Court has held that a taxpayer has a right to conduct an examination of Internal Revenue Service officials regarding their reasons for issuing a summons when he points to specific facts or circumstances plausibly raising an inference of bad faith.

In a brief filed with the court on March 17, 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.

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