Tax Insights: US Supreme Court creates new rule for IRS summons enforcement

The US Supreme Court, in a unanimous opinion issued June 19, 2014, implemented a new standard for courts to employ in determining if a taxpayer may challenge whether the Internal Revenue Service has issued a summons in good faith. In light of the Service’s new procedures for administering Information Document Requests, including the potential for summons enforcement, this opinion provides important guidance to taxpayers who may find themselves in the midst of a summons enforcement action.