Polselli v. Internal Revenue Service
Supreme Court of the United States
Decided May 18, 2023
Full case name	Polselli v. Internal Revenue Service
Docket no.	21-1599
Citations	598 U.S. ___ (more)
Holding
When the Internal Revenue Service issues a summons in aid of collecting a tax liability, the exception to the notice requirement in 26 U.S.C. § 7609(c)(2)(D)(i) applies even if the delinquent taxpayer has no legal interest in the accounts or records summoned.
Court membership
Chief Justice John Roberts Associate Justices Clarence Thomas · Samuel Alito Sonia Sotomayor · Elena Kagan Neil Gorsuch · Brett Kavanaugh Amy Coney Barrett · Ketanji Brown Jackson
Case opinion
Majority	Roberts, joined by unanimous

Polselli v. Internal Revenue Service, 598 U.S. ___ (2023), was a United States Supreme Court case in which the Court held that when the Internal Revenue Service issues a summons in aid of collecting a tax liability, the exception to the notice requirement in 26 U.S.C. § 7609(c)(2)(D)(i) applies even if the delinquent taxpayer has no legal interest in the accounts or records summoned.^[1][2]

• Text of Polselli v. Internal Revenue Service, No. 21-1599, 598 U.S. ___ (2023) is available from: Justia

This article incorporates written opinion of a United States federal court. As a work of the U.S. federal government, the text is in the public domain. "[T]he Court is unanimously of opinion that no reporter has or can have any copyright in the written opinions delivered by this Court." Wheaton v. Peters, 33 U.S. (8 Pet.) 591, 668 (1834)

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