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J.B. v. U.S.

No. 16-15999.

916 F.3d 1161 (2019)

J.B.; P.B., Petitioners-Appellees, v. UNITED STATES of America, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Filed February 26, 2019.

Attorney(s) appearing for the Case

Nathaniel S. Pollock (argued), Robert W. Metzler , and Michael J. Huangs , Attorneys; Caroline D. Ciraolo , Principal Deputy Assistant Attorney General; David A. Hubbert , Acting Assistant Attorney General; Brian Stretch , United States Attorney; United States Department of Justice, Washington, D.C.; for Respondent-Appellant.

Norren Evans (argued), O'Brien Watters & Davis LLP, Santa Rosa, California; Sara Baxter and Joseph Baxter , Santa Rosa, California; for Petitioners-Appellees.

Felipe S. Bohnet-Gomez , Steven T. Miller , and Dean A. Zerbe , Zerbe Miller Fingeret Frank & Jadav LLP, Washington, D.C., for Amicus Curiae Zerbe Miller Fingeret Frank & Jadav LLP.

Before: Kim McLane Wardlaw and Jacqueline H. Nguyen, Circuit Judges, and Solomon Oliver, Jr., District Judge.

OPINION

Before the Internal Revenue Service (IRS) summons a taxpayer's financial records from employers, financial institutions, or other third parties, the IRS must provide the taxpayer with "reasonable notice in advance." 26 U.S.C. § 7602(c)(1).1 Our Circuit has yet to determine...

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