powell-framework

1 cases — ← All topics

Case Title Lower Court Docketed Status Flags Tags Question Presented
22-1179 Sabena Puri v. United States Ninth Circuit 2023-06-06 Denied Response Waived abuse-of-process foreign-government-inquiry good-faith irs-summons judicial-process judicial-review powell-framework tax-treaty treaty-request united-states-v-powell united-states-v-stuart Is a foreign government's abusive or bad faith purpose ever relevant to the enforcement of an IRS summons issued pursuant to a treaty request?