Whether a law firm can be denied the opportunity to challenge an IRS summons for law firm trust account records based solely on an IRS declaration, and whether an allegation of bad faith actions by an IRS employee approved by a manager is sufficient to show agency bad faith requiring an evidentiary hearing

1. Whether a law firm can be denied the opportunity to challenge an IRS summons for law firm trust account records based solely on an IRS declaration which states only in general terms that the summons would aid IRS in the collection of taxes owed by a law firm employee. 2. Whether an allegation of bad faith actions by an IRS employee that were approved by an IRS manager is sufficient to show bad faith by the agency thereby requiring an evidentiary hearing.