No Notice Needed on IRS Bank Summonses Tied to Lawyers, Wife (1)

The U.S. is protected from a lawsuit over IRS summonses to the banks of a taxpayer’s wife and lawyers because the government wasn’t required to notify the bank account holders, a divided appeals court panel ruled.

The ruling, from the U.S. Court of Appeals for the Sixth Circuit, held that the U.S. was protected from the lawsuit by sovereign immunity, which the government has only waived when a taxpayer who was entitled to notice challenges a summons. The question of how to interpret the notice requirement has split federal appeals courts, with the U.S. Courts ...