Supreme Court of the United States

Polselli v. IRS

May 18, 2023598 U.S. 432

Summary

The 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, affirming the Sixth Circuit and rejecting the petitioners’ legal‑interest test.