On November 12th, 2013 the United States District Court for the Southern District of Texas issued a decision in Trowbridge v. Internal Revenue Service (Civil Action No. 4:13-cv-1850, Nov. 12, 2013). The case involved the notice requirement for I.R.S. summonses to third parties under § 7609. Typically, the IRS must provide notice to the subject of an audit when an administrative summons is issued to a third party. The Service can forgo such notice, however, when the third party is an employee of the audited taxpayer. In Trowbridge, the taxpayer attempted to quash a summons for testimony and documents issued to one of his employees. The Court found that the taxpayer was not entitled to notice, and had no standing to challenge the summons.
District Court in Trowbridge Rules Taxpayer Lacks Standing to Quash Summons issued to Taxpayer Employee
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