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Jeremy H. Temkin Jeremy H. Temkin

First authorized by the Supreme Court in United States v. Bisceglia, 420 U.S. 141 (1975), and subsequently codified by Congress at §7609(f) of the Internal Revenue Code, John Doe summonses have long been a powerful tool in the IRS’s arsenal to combat tax fraud schemes. These summonses enable the IRS to seek data on a class of otherwise unidentified persons (e.g., customers of a specific bank) where it can articulate a reasonable basis to believe that individuals within that class have failed to comply with their tax obligations.

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