26 U.S.C. § 7601
Canvass of districts for taxable persons and objects
The Secretary shall, to the extent he deems it practicable, cause officers or employees of the Treasury Department to proceed, from time to time, through each internal revenue district and inquire after and concerning all persons therein who may be liable to pay any internal revenue tax, and all persons owning or having the care and management of any objects with respect to which any tax is imposed.
For penalties applicable to forcible obstruction or hindrance of Treasury officers or employees in the performance of their duties, see section 7212.
1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary”.
Notes of Decisions
Cited in 95
cases (11 in the last 5 years), 1956–2023 · leading case: United States v. Rodgers, 461 U.S. 677 (1983).
United States v. Rodgers, 461 U.S. 677 (1983). “141, 145-146 (1975) ( 26 U. S. C. §§ 7601 , 7602); United States v.”
United States v. Euge, 444 U.S. 707 (1980). “26 U. S. C. § 7601 (a). Congress has legislated that the Secretary is "required to make the inquiries, determinations, and assessments of all taxes .”
United States v. Richey, 632 F.3d 559 (9th Cir. 2011). “26 U.S.C. § 7601 . In order to ascertain “the correctness of any return,” the IRS may issue a summons for records and documents from third parties in connection with a tax liability investigation.”
Slodov v. United States, 436 U.S. 238 (1978). “” 26 U. S. C. § 7601 (a). There is no general requirement that the withheld sums be segregated from the employer’s general funds, however, or that they be deposited in a separate bank account until required to be paid to the Treasury.”
Kimberly Gaetano v. United States, 994 F.3d 501 (6th Cir. 2021). “” 26 U.S.C. § 7601 (a). In conducting its investigations, the IRS is authorized by statute to summon not only the person under investigation, but also any third-party the IRS “may deem proper” to obtain information “as may be relevant or material” to an IRS investigation.”
United States v. F. Thomas Little, United States of Am. v. Peter Chernik, United States of Am. v. Harold Grutchfield, 753 F.2d 1420 (9th Cir. 1985). “Congress also gave the IRS a broad mandate to investigate all persons who may be liable for any internal revenue tax, 26 U.S.C. § 7601 , and broad discretion in determining what “reasonable devices or methods” may be “necessary or helpful” in collecting revenue tax.”
Stephen Tornay, Galene Tornay v. United States of Am. A.R. Demeter, Special Agent, Internal Revenue Serv., 840 F.2d 1424 (9th Cir. 1988). “26 U.S.C. § 7601 (1982). This includes issuing summonses for any material that is relevant to an investigation.”
United States v. Brown, 349 F. Supp. 420 (N.D. Ill. 1972). “s court is persuaded that the work product doctrine is applicable in IRS enforcement proceedings, the application of the work product doctrine in IRS enforcement proceedings requires that the work product doctrine as promulgated in Hickman be tailored to reflect the important…”
John E. Codner v. United States, 17 F.3d 1331 (10th Cir. 1994). “After concluding that IRS had complied with the statutory requirements applicable to issuance of the remaining six summonses, the district court denied Codner’s petition to quash and granted IRS’s petition to enforce these summonses. Codner appeals.”
In re Grand Jury Investigation William H. Pflaumer & Sons, Inc., 53 F.R.D. 464 (E.D. Pa. 1971). “The second ground of the motion is that the very same records had been previously sought by an IRS summons in proceedings pursuant to 26 U.S.C. § 7601 et seq., and that the government was using the grand jury subpoena as a mere subterfuge to get the records for the IRS.”
Tiedemann v. Superior Court, 83 Cal. App. 3d 918 (Cal. Ct. App. 1978). “(7) In applying the foregoing principles, we first determine that proceedings undertaken by an official investigative and enforcement branch of the Internal Revenue Service, whose broad duties imposed by law ( 26 U.S.C. § 7601 et seq.) include authority to conduct investigations…”
In Re April 1977 Grand Jury Subpoenas. Gen. Motors Corp. v. United States, 584 F.2d 1366 (6th Cir. 1978). “26 U.S.C. § 7601 et seq. It also appears from the ABA article that Congress has been looking into grand jury abuse since 1973, and that both Senate and House Committees have conducted extensive hearings.”
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