Summons Power of the Internal Revenue Service Is Not Limited to Investigations Focusing Upon a Particular Person, Return, or Potential Tax Liability

Date

1975

Journal Title

Journal ISSN

Volume Title

Publisher

Texas Tech Law Review

Abstract

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.

Description

Keywords

Taxation, Section 7602, Investigation, IRS, Internal Revenue Service, Internal Revenue Code of 1954, United States v. Bisceglia, Case note

Citation

7 Tex. Tech L. Rev. 207