Polselli v. Internal Revenue Service, 598 U.S. 432 (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.
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