Hanna Karcho Polselli, et al., Petitioners v. Internal Revenue Service

  1. December 21, 2023

    Top Federal Tax Cases Of 2023

    IRS procedures played a key role in tax-related litigation this year, with the U.S. Supreme Court affirming a decision to allow agency summonses for a law firm's banking records and the Sixth Circuit tossing aside a prior decision vacating an IRS enforcement notice. Here, Law360 reviews some of the most significant federal tax decisions of 2023.

  2. July 03, 2023

    Top Federal Tax Cases In 1st Half Of 2023

    The Internal Revenue Service's authority to assess penalties tied to foreign information returns was the subject of notable federal tax decisions in the first half of 2023, while the U.S. Supreme Court maintained the agency's power to issue third-party summonses without prior notification. Here, Law360 reviews significant tax rulings by federal courts in the past six months.

  3. May 18, 2023

    IRS Needn't Notify Firms Of Bank Doc Summons, Justices Say

    The U.S. Supreme Court affirmed Thursday a Sixth Circuit decision approving IRS summonses for the banking records of two law firms and the wife of a man owing $2 million in taxes, rejecting their arguments that they should have been notified of the requests.

  4. March 29, 2023

    Justices Press Gov't On IRS Silence About Firm Summonses

    Multiple U.S. Supreme Court justices scrutinized the government's arguments Wednesday that the IRS may seek the bank records of two firms and the wife of a man owing $2 million without notifying them, with one questioning the agency's need to "impose secrecy" on third parties.

  5. March 28, 2023

    High Court May Define When IRS Can Keep Summonses Quiet

    The U.S. Supreme Court is slated to hear arguments Wednesday over IRS summonses seeking the banking records of two law firms and the wife of a tax debtor, in a case that could delineate the agency's ability to issue third-party summonses without notice.

  6. March 21, 2023

    Firms Urge Justices To Nix 6th Circ. OK Of IRS Summonses

    The U.S. Supreme Court should reverse a Sixth Circuit decision permitting the IRS to go ahead with summonses for the banking records of two law firms and the wife of a man owing $2 million in taxes, the firms and the woman told the justices.

  7. February 23, 2023

    Justices Urged To Affirm 6th Circ. OK Of IRS Firm Summonses

    The U.S. Supreme Court should affirm a Sixth Circuit decision finding the IRS could proceed with summonses seeking the banking records of two law firms and the spouse of a man owing $2 million in taxes without notifying them of the requests, the U.S. government argued.

  8. January 31, 2023

    Chamber, ACLU Urge Justices To Limit IRS Summons Power

    The Internal Revenue Service infringed on the civil rights of taxpayers by expanding its summons power to obtain taxpayer records from third parties without warning, groups including the U.S. Chamber of Commerce and American Civil Liberties Union said in amicus briefs filed at the U.S. Supreme Court.

  9. January 02, 2023

    Federal Tax Cases To Watch In 2023

    In the coming year, the U.S. Supreme Court will hear multiple high-profile tax cases involving attorney-client privilege and foreign bank account penalties, while lower courts will continue to grapple with the legitimacy of IRS rulemaking. Here, Law360 reviews the top federal tax cases to watch in 2023.

  10. December 09, 2022

    Justices To Review Firms' IRS Bank Summonses Dispute

    The U.S. Supreme Court said Friday it will consider whether the Internal Revenue Service can proceed with summonses seeking the banking records of two law firms and the spouse of a man owing $2 million in taxes without informing them of the requests.