The court in Hibben v. United States, 2009 U.S. Dist. LEXIS 78699 (M.D. Tenn. 2009) relied on Professor Camp's research regarding the legislative history of the summons power to counter a taxpayer's claims about how that power was limited. The court cited to Camp's article Tax Administration as Inquisitorial Process and the Partial Paradigm Shift in the 1998 IRS Restructuring and Reform Act, 56 Fla. L. Rev. 1 (2004), describing it as "in depth."