Extract to table

26 must be narrowed in order for PPC to provide a meaningful, targeted, and timely response

These principles reflect the basic requirement that IDRs must be tailored to the matters actually under examination and must be proportionate in scope to the significance and complexity of the issues being investigated

While PPC acknowledges that the IRS's examination authority under Section 7602 of the Internal Revenue Code is broad and encompasses the power to examine books, records, and other data relevant to the determination of the correctness of a taxpayer's return, that authority must be exercised reasonably and in proportion to the issues being examined

48, 57–58 (1964) (IRS must demonstrate that an investigation is conducted for a legitimate purpose and that the materials sought are relevant to that purpose); United States v