LLC v. United States Dept. of Treasury, I.R.S., 570 F.3d 1244, 1248 (11th Cir.2009) (recognizing “Service’s obligation to administer and enforce Congress’ power to lay and collect taxes.”). Further, the Supreme Court “has consistently construed congressional intent to require that if the summons authority claimed is necessary for the effective performance of congressionally imposed responsibilities to enforce the tax Code, that authority should be upheld absent express statutory prohibition or substantial countervailing policies.” United States v. Euge, 444 U.S. 707, 711, 100 S.Ct. 874, 63 L.Ed.2d 141 (1980). The IRS need not prove that the Tribe actually failed to properly withhold taxes and report payments to obtain enforcement of a summons. Cf. Powell, 379 U.S. at 57, 85 S.Ct. 248 (<HOLDING>). See also United States v. White, 853 F.2d
holding that the objective standard for determining probable cause obviates the need to analyze the officers subjective motivation holding that new york law reasonable cause standard is equivalent to fourth amendments probable cause standard holding that a summons is sufficient restraint to invoke probable cause requirement where failure to appear on summons may result in issuance of warrant holding irs need not meet any standard of probable cause to obtain enforcement of a summons   holding that in a  1983 action issue of probable cause is for the jury