IRS summons


IRS Summons Reaches Attorney’s Client Names

Communications with an attorney are generally protected from disclosure.  But what about client names?  And what power does the IRS have the power to force an attorney to disclose the names of his clients?  The court addressed this in U.S. …..

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Can IRS Cure Defective Summons With Second Summons?

The administrative summons is one of the IRS’s primary tools for obtaining information from taxpayers and third parties. There are very few requirements that the IRS has to satisfy in issuing summones. In Maxcrest Limited v. United States, Case No. 15-mc-80270-JST, the U.S. District Court for the Northern District of California addressed whether the IRS […]

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Court Says Five IRS Audits in Ten Years is Not Harassment

In Appenrodt v. United States, No. 3:16-cv-02010-LB (N.D. Cal. 2016), the court concluded that the IRS did not harass a taxpayer by subjecting the taxpayer to five audits in ten years. The facts and procedural history of the case are as follows: The IRS audited Mr. Appenrodt’s individual income tax returns for tax years 2005-2008.[…]

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Choosing Not to Comply With an IRS Summons

The law requires taxpayers to keep certain records. The IRS expects taxpayers to produce these records on request. The IRS has the power to issue an administrative summons if the taxpayer does not cooperate. This begs the question as to what happens if…


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