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District Court Grants Summary Judgment for Government on § 7431 Wrongful Disclosure Claims to Third Party Recordkeepers but Not Other Third Party Summonses (10/13/20)

In Williams Dev. & Constr. v. United States, 2020 U.S. Dist. LEXIS 187212 (D. S.D. 10/8/20), CL here, the IRS Criminal Investigation (“CI”) agent issued 15 IRS administrative summonses falling into two relevant categories:  (i) third party recordkeeper summonses (here to financial institutions) and (ii) third party summonses that are not third party recordkeeper summonses.  […]

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U.S. Brings Summons Enforcement Suit against Del. Dept of Insurance re Micro-Captives (6/23/20)

DOJ Tax has brought a summons enforcement suit against the Delaware Department of Insurance (“DDOI”) to obtain documents and testimony that DDOI has failed to provide regardomg microcaptive insurance companies.  United States v. Delaware Department of Insurance (D. Del. Dkt. 1:20-cv-00829).  The petition and IRS agent declaration are available on CourtListener here and here.  The […]