Case: U.S. District Court Rules IRS May Have Violated Privacy Act by Failing to Notify Taxpayer of Bank Summons

The U.S. District Court held that the IRS’s failure to properly notify the taxpayer of a third-party summons issued to his bank may have violated the Right to Financial Privacy Act (RFPA), denying the IRS’s motion to dismiss. Taxpayer, an individual, alleged that the IRS sent a summons notice to his old address despite his updated address being on file. The IRS had previously sent correspondence to both his old and new addresses. The court held that the taxpayer plausibly alleged the IRS failed to comply with the notice procedures required by IRC §7609 for third-party summonses. The court determined ...