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Article: The "solely criminal purpose" defense to the enforcement of IRS summonses.
- Article from:
- Michigan Law Review
- Article date:
- June 1, 1997
- Author:
CopyrightCOPYRIGHT 1997 Michigan Law Review Association. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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INTRODUCTION
Recent years have witnessed a gradual erosion of the practical distinctions between the civil and criminal investigations performed by federal administrative agencies.(1) This trend arose naturally from a growing number of federal statutes and regulations that carry both civil and criminal penalties for their violation.(2) Administrative agencies today wield investigative summons power(3) almost as expansive as the grand jury subpoena power(4) and can use that power to investigate without first deciding whether criminal or civil liability ultimately will be sought.(5)
The Internal Revenue Service (IRS) has participated to some extent ...