26 U.S.C. § 6903
Notice of fiduciary relationship
Upon notice to the Secretary that any person is acting for another person in a fiduciary capacity, such fiduciary shall assume the powers, rights, duties, and privileges of such other person in respect of a tax imposed by this title (except as otherwise specifically provided and except that the tax shall be collected from the estate of such other person), until notice is given that the fiduciary capacity has terminated.
Notice under this section shall be given in accordance with regulations prescribed by the Secretary.
1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary” wherever appearing.
Notes of Decisions
Cited in 6
cases (1 in the last 5 years), 1959–2024 · leading case: Rob Evans & Assocs., LLC v. United States, 9 F. Supp. 3d 165 (D. Mass. 2014).
Rob Evans & Assocs., LLC v. United States, 9 F. Supp. 3d 165 (D. Mass. 2014). “In filing the refund claim, Plaintiff did so in the name of the QSF, not in the name of the Puccios. Though *169 Defendant raises this error now, it did not use this error as a basis to deny Plaintiff’s claim.”
United States v. Pugach, 388 F. Supp. 1091 (S.D.N.Y. 1974). “Under Title 26 U.S.C. § 6903 and accompanying Regulations, every person who is acting for another person in a fiduciary capacity is required to give notice thereof to the District Director of the Internal Revenue Service.”
Williams v. United States, 264 F.2d 227 (6th Cir. 1959). “Code, § 6903, 26 U.S.C.A. § 6903 , the Commissioner of Internal Revenue sent the challenged notice of deficiency by registered mail addressed to the taxpayer in care of and at the address of the attorney in fact as requested and directed in the power of attorney on file.”
United States v. Brooks, 164 F.R.D. 501 (D. Or. 1995). “26 U.S.C. § 6903 (a). A tax dispute is between the taxpayer and the United States alone, even if a third person is directly impacted by the eventual outcome.”
Vaughn v. United States (Fed. Cl. 2024). “Plaintiff appears to rely on 26 U.S.C. § 6903 (a) for his breach of fiduciary duty claim.”
Gunther v. United States, 573 F. Supp. 126 (W.D. Mich. 1982). “26 U.S.C. § 6903 (a). Section 7701(a)(6) defines a fiduciary as “a guardian, trustee, executor, administrator, receiver, conservator, or any person acting in any fiduciary capacity for any person” 26 U.”
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