United States v. Robert Julian

DUBINA, Circuit Judge:

This. consolidated appeal returns to us from the district court on remand from the United States Supreme Court. In Clarke, the Supreme Court vacated and remanded our previous opinion, United States v. Clarke (Clarke I), 517 Fed.Appx. 689 (11th Cir.2013), and provided a clear standard under which a taxpayer is entitled to an evidentiary hearing to examine Internal Revenue Service (“IRS”) agents concerning their motives for issuing a summons. United States v. Clarke (Clarke), 573 U.S. —, —, 134 S.Ct. 2361, 2367-68, 189 L.Ed.2d 330 (2014). We remanded the case to the…