Is the United States Internal Revenue Service1 summons process subject to quashing and constraint by operation of the First Amendment as interpreted through this Court's line of prece-dents governing use of regulation and investigation t actics to chill or retaliate against disfavored First Amendment expression, includ-ing, inter alia, Bantam Books, Inc. v. Sullivan,2 303 Creative LLC v. Elenis,3 and this Court's pending decision in Missouri v. Biden4?5

In light of statements in U.S. v. Clarke ,9 and U.S. v. Powell10 that tax summonses may be quashed or stayed "on any appropriate ground" and not just those in the core Powell factor test, may a taxpayer invoke as independent and/or additional bases for quashing an IRS summons the standards from the Bantam Precedents and/or other precedents and the post- Powell 26 U.S.C. § 7602(e) statute11 (prohibiting "use" of a "financial status or economic reality examination technique[]" to try to "determine the exist-ence of unreported income of any taxpayer" without "a reasonable ind ication that there is a likelihood of such unreported income")?

Can an IRS agent obtaining IRS summonses enforcement rest his articulation of support for a purportedly legitimate Powell purpose in a Clarke declaration13 solely upon the agents' own declaration assertion of a purported verbal confession from a targeted taxpayer who denies

Whether the IRS summons process is subject to quashing and constraint by the First Amendment's protections against chilling or retaliatory government investigations