was a dual-purpose summons, we need not answer the question whether the additional information sought from Ritchie by the IRS was "relevant to a legitimate investigation” of his firm. 8 . The statutory protections are not strong in any event; the prior approval required is not difficult to obtain because it is given ex parte solely on the basis of the petition and supporting affidavits. See I.R.C. § 7609(h)(2). 9 . We also note that it has been held that "the criteria in 26 U.S.C. § 7609(f) governing ex parte issuance of a John Doe summons pursuant to 26 U.S.C. § 7609(h)(1) are not appropriate grounds to challenge enforcement of the summons." In re Does, 688 F.2d 144, 145-46 (2d Cir.1982) (footnote omitted). But see United States v. Brigham Young Univ., 679 F.2d 1345 (10th Cir.1982) (<HOLDING>), vacated and remanded (for consideration of
holding that the summoned party may in an enforcement proceeding challenge the  7609f2 determination that there is a reasonable basis for believing there may be a violation of a revenue law holding that the alj is not obliged to accept an iq if there is a substantial basis in the record for believing that the claimant was feigning the results holding that there was no justiciable controversy and that while many laws may be easily subject to challenge we may only review such matters in a proper law suit holding that a party may be liable under  1447c only where the removing party lacked an objectively reasonable basis for seeking removal holding that there is a rational basis for the distinction