Tax,
U.S. Supreme Court
May 23, 2023
Polselli, et. al., v. Internal Revenue Service – is it a blank check?
While this case may not be entirely a blank check to the IRS to issue summons without notice because the Court leaves open the issue of defining boundaries of “in aid of the collection,” the IRS has no incentive to treat this case as anything other than a blank check until there is further caselaw on the matter.
Internal Revenue Code (“IRC”) §7609(c)(2)(D)(i) indicates, with respect to giving notice to a person identified on an IRS summons, no notice is required if:
(D) issued in aid of the collection of—
(i) an assessment made or judgment rendered against the person with respect to whose liability the summons is issued; or …
The aforementioned subsection serves as the basis of the exclusi...
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