U.S. Supreme Court To Address the IRS’s Summons Authority

January 18, 2023  |  New York Law Journal

The current Supreme Court term promises to be an especially important one for tax practitioners. Among other matters, the Court recently agreed to hear Polselli v. IRS, which presents a two-decade old Circuit split regarding the scope of the IRS’s obligation to provide notice to third parties when it issues summonses in connection with attempts to collect past due taxes. In this article we discuss the approaches taken by different Circuit Courts of Appeals in interpreting the relevant statute and the Supreme Court’s decision to take on an important issue concerning the scope of the IRS’s summons authority and procedures in a case that offers it an opportunity to further develop the jurisprudence governing statutory interpretation.

U.S. Supreme Court To Address the IRS’s Summons Authority (pdf | 227.80 KB)