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Resolving a decades-old circuit court split on Internal Revenue Service (IRS) summons authority, on May 18, 2023, the U.S. Supreme Court issued a unanimous decision in Polselli v. Internal Revenue Service granting the IRS broad power to summons third parties to aid in the collection of a tax debt without giving notice to the account holders.

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Tags: GT Insight, IRC, IRS, IRS summons, U.S. Supreme Court
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Photo of Michelle Ferreira Michelle Ferreira

G. Michelle Ferreira is Co-Managing Shareholder of the San Francisco Office and Co-Managing Shareholder of the Silicon Valley Office and counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California

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G. Michelle Ferreira is Co-Managing Shareholder of the San Francisco Office and Co-Managing Shareholder of the Silicon Valley Office and counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California Franchise Tax Board, the State Board of Equalization, the Employment Development Department and county assessment appeals boards.

As a former tax litigator for the Internal Revenue Service, Michelle brings unique experience to clients who have complex and sensitive tax and penalty disputes. Michelle represents clients before the IRS, and state and local tax agencies at the audit, collection, appeals and litigation stages.

Michelle has 18 reported decisions in the U.S. Tax Court on issues such as unreported income, family limited partnerships, civil and criminal tax fraud, penalty assessments, statutes of limitation assertions, valuation disputes, controversies involving valuation discounts for lack of control and lack of marketability, tax shelters, hobby losses, complex real estate transactions, tax structured transactions, and unsubstantiated business expenses.

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Photo of Scott E. Fink Scott E. Fink

Scott E. Fink focuses on civil and criminal federal and state tax controversies and litigation. He represents corporations, partnerships, estates and individuals before the Internal Revenue Service, and state and local tax authorities in examinations, collection problems, administrative appeals, and in court.

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Photo of Barbara T. Kaplan Barbara T. Kaplan

Barbara T. Kaplan is Co-Chair of the Global Tax Practice and has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals…

Barbara T. Kaplan is Co-Chair of the Global Tax Practice and has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies and litigation, including administrative and grand jury criminal tax investigations.

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Photo of Jennifer A. Vincent Jennifer A. Vincent

Jennifer A. Vincent focuses on federal and state tax controversies and litigation. Ms. Vincent represents both individuals and companies in proceedings before the Internal Revenue Service and before California taxing authorities, including the Franchise Tax Board and the California Department of Tax and…

Jennifer A. Vincent focuses on federal and state tax controversies and litigation. Ms. Vincent represents both individuals and companies in proceedings before the Internal Revenue Service and before California taxing authorities, including the Franchise Tax Board and the California Department of Tax and Fee Administration. She also assists clients with compliance counseling for both federal and state-based tax issues.

Ms. Vincent has considerable experience in defending clients in federal offshore audits and income tax examinations and in California income, sales and use tax, and property tax matters.

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