Polselli v. Internal Revenue Service, No. 21-1599 [Arg: 03.29.2023]
Supreme Court of the United States
English - March 30, 2023 16:37 - 50 minutes - 23.1 MB - ★★★★★ - 2 ratingsPolitics News justice supreme court usa united states docket Homepage Download Apple Podcasts Google Podcasts Overcast Castro Pocket Casts RSS feed
Previous Episode: Samia v. U.S., No. 22-196 [Arg: 03.29.2023]
Issue(s): Whether 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 only when the delinquent taxpayer owns or has a legal interest in the summonsed records, as the U.S. Court of Appeals for the 9th Circuit has held, or whether the exception 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, as the U.S. Courts of Appeals for the 6th and 7th Circuits have held.