U.S. District Court Dismisses Motion to Quash IRS Bank Summons for Collection Activities

The U.S. District Court for the Northern District of Ohio dismissed the taxpayer’s motion to quash an IRS summons, issued to a bank, due to lack of jurisdiction because the summons was issued in aid of collection rather than determination of tax liability. The taxpayer challenged an IRS summons to his bank regarding a $38 million tax levy that had been imposed against him. Although the levy was temporarily released while the taxpayer participated in the Collection Appeal Program, the taxpayer alleged that the IRS breached its agreement not to pursue collection actions during the appeal process. Upon review, the ...