A sign is displayed outside the Internal Revenue Service building May 4, 2021, in Washington. Photo: Patrick Semansky/AP U.S. Supreme Court To Address the IRS's Summons Authority
On Dec. 9, 2022, the court granted a writ of certiorari in 'Polselli v. IRS' to address a two-decade old Circuit split regarding the scope of the Internal Revenue Service's obligation to provide notice when it seeks records in connection with its efforts to collect past due taxes.
January 18, 2023 at 10:00 AM
9 minute read
The current U.S. Supreme Court term promises to be an especially important one for tax practitioners. In addition to the recent arguments in Bittner v. United States, No. 21-1195 (argued Nov. 2, 2022) (addressing the penalties that can be imposed for non-willful FBAR violations) and In re Grand Jury, No. 21-1397 (argued Jan. 9, 2023) (addressing the application of the attorney-client privilege to communications that include tax-preparation advice), on Dec. 9, 2022, the court granted a writ of certiorari in Polselli v. IRS, No. 21-1599, to address a two-decade old Circuit split regarding the scope of the Internal Revenue Service's obligation to provide notice when it seeks records in connection with its efforts to collect past due taxes. This column discusses the approaches taken by different Circuit Courts of Appeals and the Supreme Court's decision to resolve the circuit split.
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