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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.

DateProceedings and Orders (key to color coding)
Jun 24 2022Petition for a writ of certiorari filed. (Response due July 28, 2022)
Jul 19 2022Motion to extend the time to file a response from July 28, 2022 to August 29, 2022, submitted to The Clerk.
Jul 20 2022Motion to extend the time to file a response is granted and the time is extended to and including August 29, 2022.
Jul 28 2022Brief amicus curiae of Center for Taxpayer Rights filed.
Aug 18 2022Motion to extend the time to file a response from August 29, 2022 to September 29, 2022, submitted to The Clerk.
Aug 19 2022Motion to extend the time to file a response is granted and the time is further extended to and including September 29, 2022.
Sep 21 2022Motion to extend the time to file a response from September 29, 2022 to October 27, 2022, submitted to The Clerk.
Sep 23 2022Motion to extend the time to file a response is granted and the time is further extended to and including October 27, 2022.
Oct 27 2022Brief of respondent Internal Revenue Service in opposition filed.
Nov 15 2022DISTRIBUTED for Conference of 12/2/2022.
Nov 15 2022Reply of petitioners Hanna Karcho Polselli, et al. filed. (Distributed)
Dec 05 2022DISTRIBUTED for Conference of 12/9/2022.
Dec 09 2022Petition GRANTED.
Jan 19 2023Motion to dispense with printing the joint appendix filed by petitioners Hanna Karcho Polselli, et al.
Jan 23 2023Brief of petitioners Hanna Karcho Polselli, et al. filed.
Jan 30 2023Brief amici curiae of Center for Taxpayer Rights, et al. filed.
Jan 30 2023Brief amicus curiae of The Chamber of Commerce of the United States of America filed.
Jan 30 2023Brief amicus curiae of National Taxpayers Union Foundation filed.
Jan 30 2023Brief amicus curiae of Institute for Justice filed.
Jan 30 2023Brief amici curiae of The Rutherford Institute and the Cato Institute filed.
Jan 31 2023SET FOR ARGUMENT on Wednesday, March 29, 2023.
Feb 03 2023Record requested from the U.S.C.A. for the Sixth Circuit.
Feb 03 2023All records from the USCA-6th Circuit were transmitted electronically and are available on PACER.
Feb 07 2023All records from the USDC-Eastern District of Michigan are available on PACER.
Feb 13 2023CIRCULATED
Feb 21 2023Motion to dispense with printing the joint appendix filed by petitioners GRANTED.
Feb 22 2023Brief of respondent United States Department of the Treasury--Internal Revenue Service filed. (Distributed)
Mar 17 2023Reply of petitioners Hanna Karcho Polselli, et al. filed. (Distributed)