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Polselli v. Internal Revenue Service

Pending petition
Docket No. Op. Below Argument Opinion Vote Author Term
21-1599 6th Cir. TBD TBD TBD TBD TBD

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

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)