Whether the IRS summons should be quashed due to tainted investigation

QUESTIONS PRESENTED 1. Whether the district court erred under United States v. Powell, 379 U.S. 48 (1964), and United States v. Clarke, 573 U.S. 248 (2014), in enforcing the IRS summons even though the IRS admittedly already possesses summoned documents. 2. Whether the district court erred under Powell and Clarke in enforcing the IRS summons even though the IRS investigation reflects information obtained through unconstitutional searches. 3. Whether the district court erred under Powell and the principle of international comity in enforcing the IRS summons even though the summons seeks to circumvent the disclosure regime imposed by multiple foreign treaties. (i)