No. 21-1599October Term 2022Decided May 18, 2023
Polselli v. IRS
The Supreme Court held that the IRS is not required to give notice when issuing a summons for a third party's records if the summons is intended to help collect a delinquent taxpayer's assessed liability.
Case status
- Current stage
- Decided
- Latest event
- Decision released May 18, 2023
- What it's about
The Supreme Court held that the IRS is not required to give notice when issuing a summons for a third party's records if the summons is intended to help collect a delinquent taxpayer's assessed liability. This exception applies even if the delinquent taxpayer has no legal interest in the summoned records.
Question presented
Whether the exception to the notice requirement in 26 U.S.C. § 7609(c)(2)(D)(i) applies only where the delinquent taxpayer has a legal interest in accounts or records summoned by the Internal Revenue Service under 26 U.S.C. § 7602.
- Case path
United States Court of Appeals for the Sixth Circuit / Decision released May 18, 2023
- Area
Decided Supreme Court case
Documents
Related cases
Grounding
- Grounding
- Primary-source trail available.
- Note
- Plain-English explainer. Official filings and opinions remain authoritative.
- Checked
- Mar 31, 2026
- Method
- Methodology