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POLSELLI v. DEPT. OF TREASURY-INTERNAL REVENUE

No. 21-1010.

23 F.4th 616 (2022)

Hanna Karcho POLSELLI; Abraham & Rose, P.L.C.; Jerry R. Abraham, P.C., Petitioners-Appellants, v. UNITED STATES DEPARTMENT OF THE TREASURY-INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: January 7, 2022.

Attorney(s) appearing for the Case

ON BRIEF: Daniel W. Weininger , ABRAHAM & ROSE, P.L.C., Troy, Michigan, for Appellants. Michael J. Haungs , Geoffrey J. Klimas , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee.

MOORE, J., delivered the opinion of the court in which DONALD, J., joined. KETHLEDGE, J. (pp. 630-33), delivered a separate dissenting opinion.

OPINION

In pursuit of over $2 million of a taxpayer's unpaid liabilities, the IRS issued administrative summonses to the banks of the taxpayer's wife and lawyers, Petitioners in this case. The IRS did not notify Petitioners of the summonses, relying on relevant provisions of the Internal Revenue Code...

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