Polselli v. Internal Revenue Service (598 U.S. 432)
U.S. Supreme Court · decided May 18, 2023 · Supreme Court Database (Spaeth)
- Citation
- 598 U.S. 432 · 143 S. Ct. 1231
- Decided
- May 18, 2023
- Term
- October Term 2022
- Vote
- 9–0
- Majority author
- Justice Roberts
- Issue area
- Federal Taxation
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
PRELIMINARY PRINT Volume 598 U. S. Part 2 Pages 432–448 OFFICIAL REPORTS OF THE SUPREME COURT May 18, 2023 Page Proof Pending Publication REBECCA A. WOMELDORF reporter of decisions NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D.C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. Syllabus POLSELLI et al. v. INTERNAL REVENUE SERVICE certiorari to the united states court of appeals for the sixth circuit No. 21–1599. Argued March 29, 2023—Decided May 18, 2023 The Internal Revenue Service has the power to issue summonses to pur- sue unpaid federal taxes and the people who owe them. When the IRS issues a summons, it must generally provide notice to any person identi- fed in the summons, 26 U. S. C. § 7609(a)(1). Anyone entitled to such notice may then bring a motion to quash the summons, § 7609(b)(2)(A). But when the IRS issues a summons “in aid of the collection of . . . an assessment made . . . against the person with respect to whose liability the summons is issued,” no notice is required, § 7609(c)(2)(D)(i). In this case, the IRS entered official assessments against Remo Polselli for more than $2 million in unpaid taxes and penalties. Reve- nue Offcer Michael Bryant issued summonses to three banks…
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