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Polselli v. Internal Revenue Service
| Docket No. | Op. Below | Argument | Opinion | Vote | Author | Term |
|---|---|---|---|---|---|---|
| 21-1599 | 6th Cir. |
Mar 29, 2023 |
TBD | TBD | TBD | OT 2022 |
Issue: 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.
SCOTUSblog Coverage
- The IRS faces tough questioning from justices over privacy concerns in third-party summons dispute (Bobby Dexter, March 30, 2023)
- Justices will consider whether IRS can issue summons to banks of taxpayers’ relatives (among others) without notice (Bobby Dexter, March 28, 2023)
- Justices take up four new cases, including challenge to federal ban on encouraging illegal immigration (Amy Howe, December 9, 2022)
- Federal ban on inducing unlawful immigration for financial gain may get another Supreme Court test (John Elwood, December 7, 2022)
- Officers question award of post-mortem damages under Section 1983 (Kalvis Golde, July 15, 2022)
