By way of example, the discussion primarily addresses summonses issued by the Internal Revenue Service. A historical overview of the use of the administrative summons notes that the Federal judiciary's interpretation of the administrative power of investigation has been liberalized over the past half century. In 1924, the U.S. Supreme Court warned against "fishing expeditions into private papers on the mere possibility that they may disclose evidence of crime;" however, by 1943, the Supreme Court affirmed the enforcement of an administrative summons on the broad grounds that "the evidence sought by the subpoena was not plainly incompetent or irrelevant to any lawful purpose of the Secretary of Labor in the discharge of her duties under the Act." In formalizing the parameters of the broad investigative authorities it had recently created, the U.S. Supreme Court has, in effect, permitted reasonable "fishing expeditions" in order "to get information from those who best can give it and who are most interested in not doing so." Potential for abuse of administrative summons power can arise in several contexts. The process involved in the Internal Revenue Service's (IRS's) referral of a case to the Justice Department for criminal prosecution, explored in some depth by the La Salle Court (United States v. La Salle National Bank), points up the amount of latitude agents have. At least two levels of review occur after the case agent makes a recommendation for criminal prosecution. Prior to such a recommendation, however, the agent can conduct the investigation in a virtually unfettered manner, exploring whatever areas of possible criminal or civil misbehavior the agent deems worthy of investigation. In challenging administrative summonses, a person must satisfy the virtually impossible burden of demonstrating institutional bad faith. 61 footnotes