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Internal Revenue Service Summons

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Gray Reed

IRS Seeks to Enforce Summons Related to Deferred Sales Trust

Gray Reed on

We have previously spoken about monetized installment sales (“MISTs”) on Dollars & Sense.  According to the IRS, these structures typically seek to defer gains associated with the sale of an appreciated asset through the use...more

Association of Certified E-Discovery...

Does FRE 502(d) Allow a Party to Shift the Privilege Burden?

[Editor’s Note: This article has been republished with permission. It was originally published December 20, 2023 on the eDiscovery Assistant Blog] In Episode 127, on the ACEDS and eDiscovery Assistant #CaseoftheWeek, Kelly...more

Fox Rothschild LLP

IRS Going All in on Use of ArtificiaI Intelligence

Fox Rothschild LLP on

The IRS issued a news release today announcing a continued and more focused use of Artificial Intelligence (AI) to audit partnerships, large corporations and alleged tax shelter promoters. The news release follows...more

BakerHostetler

Kraken Loses Bid To Avoid Turning Over Customer Information to IRS

BakerHostetler on

In a recent ruling, a California federal judge held that Kraken, an online cryptocurrency exchange program, has to turn over user information to the IRS as a result of a John Doe summons originally served on Kraken in 2021....more

McDermott Will & Emery

The Government Flexes Its Summons Muscles

McDermott Will & Emery on

Two recent decisions confirmed the broad administrative summons authority of the Internal Revenue Service (IRS). In the first, the US Supreme Court resolved a circuit conflict regarding notice requirements for third-party IRS...more

Paul Hastings LLP

The IRS Can Obtain Your Bank Records Without Your Knowledge

Paul Hastings LLP on

The U.S. Supreme Court rules that the IRS does not need to provide notice to innocent bank account holders when the summonses are issued in aid of collection of a delinquent taxpayer’s tax assessment. ...more

Rivkin Radler LLP

Supreme Court Upholds IRS Collections Summons Without Notice

Rivkin Radler LLP on

The Supremes- The Constitution has figured prominently in the news of late. In the days preceding the initial discussions among members of the Administration and the Congressional leadership regarding the debt ceiling,...more

Dorsey & Whitney LLP

The Supreme Court Update - May 18, 2023

Dorsey & Whitney LLP on

Today, the Supreme Court of the United States issued six decisions: Amgen Inc. v. Sanofi, No. 21-757: This case addressed the Patent Act’s “enablement” requirement—the provision that requires a patent applicant to describe...more

Dorsey & Whitney LLP

The Supreme Court Update - December 9, 2022

Dorsey & Whitney LLP on

Today, the Supreme Court of the United States granted certiorari in four cases: Coinbase, Inc. v. Bielski, No. 22-105: This case presents an issue of federal arbitration law. The question presented is: Whether a...more

Cadwalader, Wickersham & Taft LLP

IRS’s Crypto John Doe Summons Expanded While Harper Fights Back

Since at least 2016 the IRS has been ferreting out taxpayers who failed to report their taxable gains from cryptocurrency transactions by issuing John Doe summonses to crypto exchanges and dealers. A John Doe summons enables...more

Freeman Law

IRS Wins Ex-Parte Petition for Another Crypto John Doe Summons

Freeman Law on

On September 21, 2022, the U.S. District Court for the Southern District of New York granted the IRS’s ex-parte motion for leave to serve a John Doe summons to M.Y. Safra Bank after the IRS’s investigation into digital asset...more

BakerHostetler

The Tax Man Isn't Leaving: The IRS Continues to Issue John Doe Summonses Relating to Virtual Currency Transactions

BakerHostetler on

Key Takeaways - ..A court approved the issuance of a John Doe summons by the IRS to a bank aimed at identifying individuals who are potentially avoiding their income tax obligations relating to cryptocurrency...more

Freeman Law

Tax Court in Brief | Lamprecht v. Comm’r | Qualified Amended Return and Foreign Banking Reporting

Freeman Law on

Tax Litigation:  The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op....more

Goodwin

Central District of California Authorizes Service of John Doe Summons on Cryptocurrency Dealer - Update

Goodwin on

​​​​​​​On August 15, 2022, the United States District Court for the Central District of California authorized the IRS to serve a “John Doe” summons on Ox Labs Inc., a cryptocurrency prime dealer doing business as SFOX....more

Goodwin

Central District of California Authorizes Service of John Doe Summons on Cryptocurrency Dealer

Goodwin on

​​​​​​​On August 15, 2022, the United States District Court for the Central District of California authorized the IRS to serve a “John Doe” summons on Ox Labs Inc., a cryptocurrency prime dealer doing business as SFOX. ...more

BakerHostetler

The Tax Man Is Back: IRS Issues First John Doe Summons in 2022 to Major Crypto Platform, Seeking Treasure Trove of Information on...

BakerHostetler on

Key Takeaways: ..The IRS issued its fourth John Doe summons against digital asset platform sFOX, seeking information regarding user identity and transaction activity over $20,000. ..The use of John Doe summonses...more

Gray Reed

IRS Continues to Hunt for Cryptocurrency Investors with John Doe Summonses

Gray Reed on

The IRS knows it has a problem, in that it knows there are far more cryptocurrency transactions than are being reported on tax returns. The IRS may also get an $80 billion increase in funding for enforcement that will help...more

Whitcomb Selinsky, PC

John Doe Summons Doesn't Violate Attorney Client Privilege

Whitcomb Selinsky, PC on

On April 24, 2020, the U.S. Court of Appeals for the Fifth Circuit published its opinion in Taylor Lohmeyer Law Firm P.L.L.C. v. United States. The Fifth Circuit court held that the Taylor Lohmeyer Law Firm (the law firm OR...more

Freeman Law

IRS Summonses and the Collection of Unpaid Taxes

Freeman Law on

This post focuses on the recent case of Polselli, et al. v. IRS, Case No. 21-1010 (6th Cir., January 7, 2022). The recent Sixth Circuit’s recent opinion in Polselli, et al. v. IRS, Case No. 21-1010 (6th Cir., January 7,...more

Freeman Law

No Right to Intervene?—IRS Third-Party Summonses

Freeman Law on

Third-party summonses. Taxpayers, individuals, and companies, alike, should be aware of the Internal Revenue Service’s (“IRS”) power to issue third-party summonses. Even more, interested parties should note that only parties...more

Freeman Law

Treasury Regulation § 301.7602-1 and Nongovernment Contractors

Freeman Law on

The IRS and Treasury Department issued a new and finalized version of Treasury Regulation § 301.7602-1. The regulations took effect on September 7, 2021, and shine a new light on nongovernment contractors’ participation in...more

Proskauer - Corporate Defense and Disputes

DOJ Tax Division Shows Continued Interest in Cryptocurrency

On May 5, 2021, another federal district court, this time for the Northern District of California, permitted the IRS to proceed with a John Doe summons very similar to the one served on Circle last month (the subject of a...more

Holland & Knight LLP

IRS Fishing Expedition Is Successful and Raises Important Attorney-Client Privilege Concerns

Holland & Knight LLP on

The attorney-client privilege is one of the bedrocks of the legal profession. It permits communications between a client and an attorney to remain privileged. The U.S. Supreme Court has stated that by assuring...more

McDermott Will & Emery

IRS Flexes Its Administrative Summons Power in Recent Tax Case

McDermott Will & Emery on

The United States Court of Appeals for the Tenth Circuit’s recent opinion in Standing Akimbo, LLC v. United States, No. 19-1049 (10th Cir. April 7, 2020), reminds us of the Internal Revenue Service’s (IRS) ability to obtain...more

Foodman CPAs & Advisors

An IRS “John Doe” Summons is a Powerful Weapon that can Puncture Attorney-Client Privilege

An individual that provides information to an attorney may normally assume that the information provided to the attorney will be kept confidential under the attorney-client privilege.  That said, according to the Internal...more

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