United States v. Clarke

573 U.S. 248, 134 S. Ct. 2361, 189 L. Ed. 2d 330 (2014)

From our private database of 45,900+ case briefs, written and edited by humans—never with AI.

United States v. Clarke

United States Supreme Court
573 U.S. 248, 134 S. Ct. 2361, 189 L. Ed. 2d 330 (2014)

Facts

The Internal Revenue Service (IRS) (plaintiff) suspected that Dynamo Holdings Limited Partnership (Dynamo) overstated its interest expenses for 2005 through 2007. Dynamo agreed to two extensions of the statute of limitations for the IRS to assess its tax liability but rejected the IRS’s third extension request. Soon thereafter, the IRS issued summonses to Michael Clarke and three other Dynamo-associated individuals (collectively, Clarke) (defendants). Clarke did not comply with the summonses. The IRS then issued proposed adjustments to Dynamo’s tax returns that would increase Dynamo’s tax liability. Dynamo challenged the proposed adjustments in the United States Tax Court in a still-pending challenge. Several months later, the IRS sued Clarke in the district court, seeking to enforce the summonses. The IRS supported its request with a declaration averring that the information it sought was necessary to properly investigate Dynamo’s tax reporting and that it did not issue the summonses for an improper purpose. Clarke responded that the IRS issued the summonses to punish Dynamo for refusing to further extend the limitations period and that the IRS sought to enforce the summonses to gain an unfair advantage in the Tax Court by evading the Tax Court’s discovery limitations. Accordingly, Clarke requested permission to interview the IRS about its motives regarding the summonses. The district court rejected Clarke’s request and ordered Clarke to comply with the summonses. Per the district court, Clarke’s statute-of-limitations theory was mere conjecture, and Clarke’s unfair-advantage theory was meritless because the propriety of a summons was determined as its issuance, which was before the Tax Court litigation commenced. The United States Court of Appeals for the Eleventh Circuit reversed, ruling that Clarke was entitled to question the IRS because Clarke alleged that the IRS was motivated by an improper purpose. The IRS appealed.

Rule of Law

Issue

Holding and Reasoning (Kagan, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 734,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 734,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 45,900 briefs, keyed to 984 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 734,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 45,900 briefs - keyed to 984 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership