Quantcast
Channel: Procedurally Taxing
Browsing latest articles
Browse All 51 View Live

In Summons Dispute IRS Entitled to Confidential Emails Between Insurance...

In US v Delaware Department of Insurance a federal district court ordered the Delaware Department of Insurance (DDOI) to turn over emails associated with micro-captive promoters.  In tax cases it is...

View Article



Polselli v US: Circuit Split on Notice Rules For Summonses to Aid Collection

The recent Sixth Circuit case Polselli v United States results in a split in the circuits on a fundamental issue in IRS summons practice: does the IRS have to give notice when it issues a summons in...

View Article

Circuit Court Holds That LLC Distinct From Its Agent For Purposes of Criminal...

In Equity Investment Associates v US the 4th Circuit considered the limits of the IRS summons power when there is a criminal investigation that relates to but does not directly involve a business...

View Article

Court Orders Enforcement Of A Summons Request From Abroad Allegedly To Harass...

Tax agencies face problems enforcing tax laws when their citizens have investments located abroad. One tool that countries use to address that problem is to include exchange of information provisions...

View Article

Polselli Summons Case Heads To Supreme Court

Last January in Circuit Split on Notice Rules For Summonses to Aid Collection I discussed how the Sixth Circuit case Polselli v United States resulted in a split in the circuits on a fundamental issue...

View Article


Supreme Court Finds For Government in Polselli Summons Litigation

Last week, in Polseilli v IRS the Supreme Court held for the government, finding that the IRS need not notify third parties when it issues a summons in the aid of collecting some other person’s tax...

View Article

District Court Affirms Constitutionality of John Doe Summons Issued To Coinbase

One of the more surprising cases of the last year involved a constitutional challenge to the IRS’s John Doe summons it issued to Coinbase. In Harper v Rettig, the investor sought an injunction...

View Article

Court Green Lights Summons Enforcement Even Though Audit Completed

US v GBX  involves a summons enforcement proceeding in the ongoing IRS attempt to crack down on alleged tax abuses stemming from conservation easements. The case highlights the government’s power to...

View Article

Browsing latest articles
Browse All 51 View Live




Latest Images