Niles Elber Discusses John Doe Summonses at NYU Tax Controversy Forum

John Doe summons can provide the IRS with an important enforcement tool to obtain the names and other information for taxpayers thought to be worthy of examination or inquiry through a source other than return filings.  John Doe summonses have their own unique procedural requirements and attributes, including judicial review and suspension of the assessment limitations period.  They can raise particular challenges and concerns when issued to law firms and others where privilege and other important considerations can come into play.  This panel will review recent cases in which John Does summonses have been issued and authorized by the courts and will consider some of the issues and challenges presented in those cases, including for both the persons receiving the summonses and the taxpayers whose information is being sought, all to provide insight and tips from practitioners as to how to handle them.