Procedurally Taxing: No Notice to Taxpayer Required When Summons Issued to Aid in Tax Collection (March 2, 2021)

Leslie Book, Professor of Law at the Villanova University Charles Widger School of Law, discusses Marra v US.

Who can bring a petition to quash a summons that the IRS has issued when it is trying to get information that would allow it to collect on an assessed tax? This is the issue in Marra v US a recent case out of the district court in Washington. In Marra, the IRS issued a summons to the taxpayer’s Chapter 7 bankruptcy trustee as part of the IRS’s efforts to find ways to collect on Marra’s $ 4 plus million assessment. The revenue officer had reason to believe the trustee had compiled information that would help the IRS track down sources to satisfy the tax debt (note the bankruptcy court had recently revoked Marra’s discharge).

To see the full article, click: “No Notice to Taxpayer Required When Summons Issued to Aid in Tax Collection.”

To download the full opinions, click: Marra v. United States ex rel. Dep’t of Treasury.

Posted by Bella Hoang, Managing Associate Editor, Wealth Strategies Journal.