Part 1 of 9 Tax Audits and Litigation Series: Motive in IRS Audits - How Does Clarke Change the Playing Field?

Date & Time: Tuesday, September 30, 2014 from 12:00 pm to 1:30 pm

CLE Credit: No

Event Description
In June the Supreme Court in United States v. Clarke granted the government's request to make it more difficult for taxpayers in the Eleventh Circuit to obtain an evidentiary hearing in a summons enforcement proceeding.  At the same time, however, the Court articulated a new standard that arguably enhances taxpayers' ability to obtain evidentiary hearings in every other Circuit.  Both sides claimed victory.  

Deborah Meland, Chief of the Civil Trial Section, Eastern Region, U.S. Department of Justice, Tax Division, Robert Kovacev of Steptoe & Johnson LLP, and Christine Hooks of Mayer Brown LLP will discuss the law of proper purpose for an IRS summons and the extent to which Clarke will have a practical impact.  The panelists will discuss issues including whether Clarke is a win for the IRS as a practical matter, whether Clarke affects a taxpayer's likelihood of ultimately avoiding a summons, and the extent to which valid claims of improper purpose can arise in contentious audit situations such as alleged retaliation, re-audits, fishing expeditions, and litigation discovery in the guise of investigation.

This luncheon program is sponsored by the Tax Audits and Litigation Committee of the Taxation Section. Doors will open at 11:30 a.m.

D.C. Bar Conference Center
1101 K Street, NW, Conference Center
(Metro Center Station)
Washington DC 20005
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Contact Information
Sections Office
Phone: 202-626-3463
Fax: 202-824-1877


  • Deborah Meland, Chief, Civil Trial Section, Eastern Region, U.S. Department of Justice, Tax Division
  • Robert J Kovacev, Partner, Steptoe & Johnson LLP
  • Christine Hooks, Associate, Mayer Brown LLP


Government Brown Bag (Please Bring Government ID)


Government/Non-Profit Employee


Law Student (Please bring student ID)


Non-Section Member


Taxation Section