Summons Power of the Internal Revenue Service Is Not Limited to Investigations Focusing Upon a Particular Person, Return, or Potential Tax Liability
Swisher, Julia K.
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Describes the United States Supreme Court case United States v. Bisceglia. In Bisceglia, the Internal Revenue Services issued a “John Doe” summons to a bank to discover the identity of the depositor of $100 bills that raises suspicion of a tax deficiency. The Court held that the Internal Revenue Services may issue a summons under section 7602 of the Internal Revenue Code of 1954 “for the purpose of an investigation focused upon a particular taxpayer, return, or liability.” The author believes that this opinion represents the Court’s proclivity for ruling for the IRS over the taxpayer.