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[21-1599] Polselli v. Internal Revenue Service
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Polselli v. Internal Revenue Service Justia (with opinion) · Docket · oyez.org Argued on Mar 29, 2023. Decided on May 18, 2023. Petitioner: Hanna Karcho Polselli, et al.. Respondent: Internal Revenue Service. Advocates: Shay Dvoretzky (for the Petitioners) Ephraim McDowell (for the Respondent) Facts of the case (from oyez.org) Remo Polselli underpaid his federal taxes for over a decade, with an outstanding balance of over $2 million. In pursuit of those unpaid liabilities, the Internal Revenue Service (IRS) issued administrative summonses to the banks of Polselli’s wife and lawyers. The IRS did not notify Polselli’s wife or lawyers of the summonses, relying on the exception in…