PRYOR, Circuit Judge:
This appeal presents three issues: (1) whether the Miccosukee Tribe may assert tribal sovereign immunity to quash summonses issued to third-party financial institutions by the Commissioner of the Internal Revenue Service to obtain tribal financial records relevant to an ongoing tax investigation; (2) whether the Commissioner issued the summonses for a proper purpose; and (3) whether the Tribe has standing to bring an overbreadth challenge to...
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