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11.14.19 | Articles, Books & Journals

John Doe Summonses: Procedural Hurdles with Limited Review

New York Law Journal

John Doe summonses have long been a powerful tool in the IRS’s arsenal to combat tax fraud schemes. Such summonses enable the IRS to seek data on a class of otherwise unidentified persons where it can articulate a reasonable basis to believe that individuals within that class have failed to comply with their tax obligations. In this article, I analyze recent decisions highlighting the heavy burden facing a party challenging a John Doe summons and discuss the potential impact of Congress’s inclusion of an additional limitation on the issuance of John Doe Summonses in the Taxpayer First Act. 

John Doe Summonses: Procedural Hurdles with Limited Review (PDF | 282.17 KB)