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Quashing an IRS Summons—Make Sure to Cross Your T’s and Dot Your I’s

In Summonses, Tax Litigation by freemanlawdevLeave a Comment

The United States District Court for the Western District of Tennessee recently issued an order dismissing a taxpayer’s petition to quash an IRS summons.[1] The case provides a lesson in the importance of certain rules that arise in the context of litigating with the government–particularly in the context of seeking to quash an IRS summons.  The court’s order found that the …

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The IRS Is Like the Soviet Hockey Team: Presley v. U.S.

In Summonses, Tax Litigation by freemanlawdevLeave a Comment

On July 18, 2018, the Eleventh Circuit issued its decision in Presley v. United States.[1]The holding of the Court focused on upholding the Internal Revenue Service’s ability to issue summonses to banks that may hold private and confidential information of third-parties. In particular, the Court held that the IRS may issue a summons to a bank to obtain a law …

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IRS Summonses Against Attorneys-What Can the IRS Compel You to Disclose?

In Summonses by Jason Freeman and Alex AillsLeave a Comment

In United States v. Servin,[1] the Third Circuit recently addressed the IRS’s authority to issue summonses against attorneys to disclose unprivileged client information. In a brief opinion, the court emphasized the IRS’s broad summonsing power—even within the attorney-client context. The court’s holding allows the IRS to compel attorneys to disclose client information absent an unusual circumstance that would cause the …