Summons

News & Analysis as of

Supreme Court to Decide When Taxpayers Can Obtain an Evidentiary Hearing in a Summons Enforcement Action

On January 10, 2014, the Supreme Court granted review of an Eleventh Circuit case addressing the circumstances under which a taxpayer can obtain an evidentiary hearing in challenging a summons issued by the Internal Revenue...more

When Your Employees Go to Court – Witness Duty

This post continues the discussion of employees absent from work for attendance at court. As a general proposition, employees who appear in court for their own cases, or on behalf of others, are not excused from work. They...more

Voluntary Disclosures Lead to John Doe Summonses for Information about U.S. Accounts at Zurcher Kantonalbank and Bank of...

In a sign that the U.S. government continues to aggressively seek information on U.S. taxpayers with non-U.S. bank accounts, the government announced on November 12, 2013, that it had obtained a court order authorizing the...more

The Claims and Litigation Process

How do you file a claim and get compensation? A lawsuit begins by filing a summons and complaint with the court and serving the defendant with a copy of the same. ...more

U.S. Seeks John Doe Summonses for Two More U.S. Banks

The Chicago Tribune reports that U.S. authorities are seeking information from Citigroup Inc.’s Citibank NA and Bank of New York Mellon Corp to uncover the identities of U.S. citizens who may have been hiding money in Swiss...more

Tax Practictioners Report Increase in Summons Issuance; IRS Issues New Guidance on Informal Document Requests

Tax practitioners have reported an increase in the issuance of IRS summonses in recent months, despite statements from the IRS indicating that it prefers informal means of investigation. Because of the intrusive nature and...more

IRS Gets “John Doe” Summons to Help Foreign Governments

In what may be a presage of actions to come the IRS has asked a court to issue a “John Doe” summons at the request of the Government of Norway. A “John Doe” summons is a court order that compels the receiving financial...more

U.S. District Court Orders Disclosure of Tax Accrual Workpapers, but Protects Opinion Work Product Information

On June 4, 2013, the U.S. District Court for the District of Minnesota held that certain information contained in tax accrual workpapers must be disclosed by the taxpayer pursuant to an Internal Revenue Service (IRS) summons,...more

IRS Denied Peek Behind the Curtain: District Court Protects Wells Fargo’s Tax Accrual Workpapers

In an important taxpayer victory, a Minnesota District Court ruled in favor of Wells Fargo, holding that the measurement and analysis of its uncertain tax positions was protected from disclosure by the work product privilege....more

In re Canopy Financial, Inc.: A Primer From the Seventh Circuit on Excusable Neglect

What is “excusable neglect” under Fed. R. Civ. P. 60(b)(1)? The answer is that it depends, but generally it’s not much. That’s the first lesson from the Seventh Circuit’s recent decision in In re Canopy Financial, Inc., No....more

Ninth Circuit Holds that Fifth Amendment Does Not Shield Taxpayer's Attorney from Forced Production of Client-Taxpayer's Records

Applying the “foregone conclusion” exception to the Fifth Amendment privilege against self-incrimination, the Ninth Circuit held on January 8, 2013, that the IRS could force a taxpayer’s criminal defense attorney to turn over...more

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