21-1599 - Polselli v. Internal Revenue Service - Opinion Announcement - May 18, 2023
A case in which the Court held that the exception in I.R.C. § 7609(c)(2)(D)(i) to the notice requirements for an Internal Revenue Service summons on third-party recordkeepers applies to a summons for anyone’s records whenever the IRS thinks that person’s records might somehow help it collect a delinquent taxpayer’s liability.