This might seem a bit far-fetched, but isn't it clear that they are determined to get them, what more evidence do they need?
Evidence?
It's nothing more than just finding some random excuse, that's all!
Gathering his scattered thoughts, Sapir continued, "Fine, if you insist on seizing this place in one go, then that's somewhat justifiable."
"But first, I want to make it clear that this club's legal person is not Mister Ditter, which means, tax evasion has nothing to do with Mister Ditter."
"Additionally, Mister Ditter is a Native American, and according to the American Federation law, Native Americans enjoy tax privileges, hence your summons for Mister Ditter might not necessarily require compliance!"
Since the IRS is set on seizing this club, what's crucial for him now isn't to quibble here but to first get Ditter out of the picture!