1. Whether the district court erred under United
States v. Powell, 379 U.S. 48 (1964), and United States
v. Clarke, 573 U.S. 248 (2014), in enforcing the IRS
summons even though the IRS admittedly already
possesses summoned documents.

2. Whether the district court erred under Powell
and Clarke in enforcing the IRS summons even
though the IRS investigation reflects information obtained through unconstitutional searches.

3. Whether the district court erred under Powell
and the principle of international comity in enforcing
the IRS summons even though the summons seeks to
circumvent the disclosure regime imposed by multiple
foreign treaties.

Whether the IRS summons should be quashed due to tainted investigation