Notice is Not Required to Assessed Taxpayer When His Bank Records are Summoned by IRS

Individual taxpayer ('TP') was found liable for $3M in income taxes. TP held most of the shares of an S Corp, received large income from it, and deposited $700K of personal funds in corp. account. IRS issued a summons to bank for S Corp's account information. TP and S Corp objected saying they were entitled to notice under 26 U.S.C. § 7609. Ninth Circuit held: An assessed taxpayer is disqualified from notice per § 7609(c)(2)(D)(i). S Corp. was disqualified from notice because of TP's large interest in S Corp.
Contributor
Robin Mashal
Los Angeles, California
Commercial Litigation
(310) 286-2000

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I am a litigation lawyer, licensed to practice law in the State of California. You can reach me by phone at (310) 286-2000.