| Litigants: | Polselli v. Internal Revenue Service |
| Decidedate: | May 18 |
| Decideyear: | 2023 |
| Fullname: | Polselli v. Internal Revenue Service |
| Usvol: | 598 |
| Uspage: | ___ |
| Docket: | 21-1599 |
| Holding: | When the Internal Revenue Service issues a summons in aid of collecting a tax liability, the exception to the notice requirement in 26 U.S.C. § 7609(c)(2)(D)(i) applies even if the delinquent taxpayer has no legal interest in the accounts or records summoned. |
| Majority: | Roberts |
| Joinmajority: | unanimous |
Polselli v. Internal Revenue Service, 598 U.S. ___ (2023), was a United States Supreme Court case in which the Court held that when the Internal Revenue Service issues a summons in aid of collecting a tax liability, the exception to the notice requirement in 26 U.S.C. § 7609(c)(2)(D)(i) applies even if the delinquent taxpayer has no legal interest in the accounts or records summoned.[1]