Polselli v. IRS

Summary

The Supreme Court held that the notice‑exception in 26 U.S.C. §7609(c)(2)(D)(i) does not require a delinquent taxpayer to have a legal interest in the records sought by the IRS. The Court affirmed the Sixth Circuit, finding that the statutory text provides three conditions for the exception and contains no limitation based on legal interest. The decision resolves a split among the circuits on the scope of the notice‑exception.