U.S. District Court Dismisses Taxpayer’s Petition to Quash IRS Summons Due to Untimeliness

The U.S. District Court for the District of South Dakota held that it lacked subject matter jurisdiction over a petition to quash an IRS summons seeking information from a bank about the petitioner’s accounts, granting the IRS’s motion to dismiss. The taxpayer, an individual, filed a petition to quash a summons issued by the IRS to Citibank for information related to his accounts, pursuant to a request from Finland’s Tax Authority, under a tax treaty. The IRS had mailed notice of the summons to the taxpayer’s last known address, but the taxpayer did not file the petition until 28 days ...