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The IRS Is Like the Soviet Hockey Team: Presley v. U.S.

In Summonses, Tax Litigation by Zach MontgomeryLeave a Comment

On July 18, 2018, the Eleventh Circuit issued its decision in Presley v. United States.[1]The holding of the Court focused on upholding the Internal Revenue Service’s ability to issue summonses to banks that may hold private and confidential information of third-parties. In particular, the Court held that the IRS may issue a summons to a bank to obtain a law …

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IRS Summonses Against Attorneys-What Can the IRS Compel You to Disclose?

In Summonses by Jason Freeman and Alex AillsLeave a Comment

In United States v. Servin,[1] the Third Circuit recently addressed the IRS’s authority to issue summonses against attorneys to disclose unprivileged client information. In a brief opinion, the court emphasized the IRS’s broad summonsing power—even within the attorney-client context. The court’s holding allows the IRS to compel attorneys to disclose client information absent an unusual circumstance that would cause the …