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 ArticlePolselli 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 ArticleCircuit 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 ArticleCourt 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 ArticlePolselli 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 ArticleSupreme 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 ArticleDistrict 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 ArticleCourt 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
More Pages to Explore .....