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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.