‘John Doe Summons’ To Law Firm Enforceable, Fifth Circuit Rules

April 24, 2020, 4:37 PM

A district court was right to enforce an IRS summons seeking documents for unidentified U.S. taxpayers from a Texas estate- and tax-planning law firm, the Fifth Circuit has ruled.

Tax code Section 7609(f) requires courts to ensure that so-called John Doe summonses—which don’t identify the person whose tax liability is the target—meet certain requirements. They must seek information that isn’t readily available elsewhere and they need to be based on a reasonable belief that a particular person or group of people might not have complied with federal tax laws.

The Taylor Lohmeyer Law Firm PLLC argued that ...

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