The Supreme Court has declined to review the Eleventh Circuit’s decision refusing a law firm’s and family limited partnership’s petition to quash IRS third-party summonses to a bank for information relating to their tax liabilities. Based on the reasoning in a companion case (Presley v. U.S., (CA 11 7/18/2018) 122 AFTR 2d 2018-5178), the Eleventh Circuit concluded that:
- The summonses were reasonable under the Fourth Amendment because clients lack a reasonable expectation of privacy in financial records held by bank; and
- Code Sec. 7609(f) procedures didn’t apply.
See full opinion at BMP Family Limited Partnership, et al. v. USA, No. 17-13645 (11th Cir. November 1, 2018) .