Supreme Court of the United States / October Term 2022

Polselli v. IRS

Decided May 18, 2023. John Glover Roberts Jr. delivered the opinion of the Court.

Docket 21-1599 · 598 U.S. 432 · Cited 14 times

Holding

When the Internal Revenue Service issues a summons pursuant to 26 U. S. C. §7602(a) in aid of collecting a tax liability, the exception to the notice requirement in §7609(c)(2)(D)(i) applies even if the delinquent taxpayer has no legal interest in the accounts or records summoned.

The Court’s statement of the holding, from the opinion’s syllabus. The syllabus is prepared by the Reporter of Decisions and is not part of the opinion of the Court — read the official opinion for authority.

Official text

Read the official opinion (PDF, supremecourt.gov) (opens primary source in a new tab)

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John Glover Roberts Jr.’s profile · All opinions since October Term 2017 · The Supreme Court

Source: Supreme Court of the United States, slip opinions (2023). Citation count from the Free Law Project’s CourtListener bulk data. Data last verified 2026-07-02. Informational only; verify against the primary source before relying. Not a consumer report (FCRA).