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Internal Revenue Code (IRC) Summons

Gray Reed

IRS Seeks to Enforce Summons Related to Deferred Sales Trust

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We have previously spoken about monetized installment sales (“MISTs”) on Dollars & Sense.  According to the IRS, these structures typically seek to defer gains associated with the sale of an appreciated asset through the use...more

McDermott Will & Emery

The Government Flexes Its Summons Muscles

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Two recent decisions confirmed the broad administrative summons authority of the Internal Revenue Service (IRS). In the first, the US Supreme Court resolved a circuit conflict regarding notice requirements for third-party IRS...more

Paul Hastings LLP

The IRS Can Obtain Your Bank Records Without Your Knowledge

Paul Hastings LLP on

The U.S. Supreme Court rules that the IRS does not need to provide notice to innocent bank account holders when the summonses are issued in aid of collection of a delinquent taxpayer’s tax assessment. ...more

Rivkin Radler LLP

Supreme Court Upholds IRS Collections Summons Without Notice

Rivkin Radler LLP on

The Supremes- The Constitution has figured prominently in the news of late. In the days preceding the initial discussions among members of the Administration and the Congressional leadership regarding the debt ceiling,...more

Freeman Law

IRS Summonses and the Collection of Unpaid Taxes

Freeman Law on

This post focuses on the recent case of Polselli, et al. v. IRS, Case No. 21-1010 (6th Cir., January 7, 2022). The recent Sixth Circuit’s recent opinion in Polselli, et al. v. IRS, Case No. 21-1010 (6th Cir., January 7,...more

Freeman Law

No Right to Intervene?—IRS Third-Party Summonses

Freeman Law on

Third-party summonses. Taxpayers, individuals, and companies, alike, should be aware of the Internal Revenue Service’s (“IRS”) power to issue third-party summonses. Even more, interested parties should note that only parties...more

Freeman Law

Treasury Regulation § 301.7602-1 and Nongovernment Contractors

Freeman Law on

The IRS and Treasury Department issued a new and finalized version of Treasury Regulation § 301.7602-1. The regulations took effect on September 7, 2021, and shine a new light on nongovernment contractors’ participation in...more

McDermott Will & Emery

IRS Flexes Its Administrative Summons Power in Recent Tax Case

McDermott Will & Emery on

The United States Court of Appeals for the Tenth Circuit’s recent opinion in Standing Akimbo, LLC v. United States, No. 19-1049 (10th Cir. April 7, 2020), reminds us of the Internal Revenue Service’s (IRS) ability to obtain...more

McDermott Will & Emery

Ninth Circuit Interprets Summons Notice Rules Strictly Against IRS

The Internal Revenue Service (IRS) had broad examination authority to determine the correct amount of tax owed by taxpayers. In addition to seeking information directly from a taxpayer, the IRS is also authorized to seek...more

Ballard Spahr LLP

2016 Year End Review: Virtual Currency: DOJ and IRS Broadly Seek Virtual Currency Account User Information

Ballard Spahr LLP on

Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more

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