Duquesne Law Review



An increasingly large number of taxpayers-guilty and innocenthave been faced with tax investigations as the Government seeks to enforce the civil and/or criminal sanctions of the Internal Revenue Code. Tax practioners representing such taxpayers have been confronted with a conflict between the demands of the Internal Revenue Service and his clients' interests. In addition, the extensive use of the administrative subpoena, the most powerful weapon in the Internal Revenue Service's arsenal, augmented by the timidity and genuflections of taxpayers and tax practitioners, and complimented by the broad construction given this weapon by the courts, have established precedents thought of by many as "the law".

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