Supreme Court rules IRS doesn’t have to give law firm notice to collect delinquent client’s assets

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The Supreme Court ruled Thursday the Internal Revenue Service did not have to give a delinquent taxpayer’s wife and law firm notice that it had summoned bank records linked to the man in an attempt to uncover and collect his assets.

Abraham & Rose PLC and Jerry R. Abraham PC represented Remo Polselli, the delinquent taxpayer, and his wife, Hanna Karcho Polselli.

The IRS had summoned the information to find the source of Mr. Polselli’s funds for paying the law firms. The feds sought roughly $2 million from him. However, some exceptions are under the Internal Revenue Code. For example, if a judgment is rendered against an individual, the IRS does not have to provide notice to a third party when it seeks records in connection with collecting on the judgment.

 

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