According to Paul Sherman, counsel for the Institute for Justice, a nonprofit public interest law firm, "The Supreme Court’s ruling grants the IRS startlingly broad authority to pry into the financial records of people who may be only remotely connected to a delinquent taxpayer."

"That ruling raises serious Fourth Amendment concerns. Thankfully, the Court stressed that its ruling was narrowly focused on the statutory question before it. In a future case, the Court should address the constitutional limits on the government’s power to demand access to people’s most sensitive financial information."