A federal district court dismissed an individual’s petition to quash third-party summonses for lack of jurisdiction. The individual failed to file his petition within 20 days of the notice of summons; therefore, his petition was untimely.
Summons Ordered Enforced
Further, the court enforced the IRS’s administrative summons. The IRS submitted a verified petition and exhibits and, therefore, made a prima facie showing for enforcement under Powell. Moreover, the individual failed to rebut the IRS’s case. Further, the summons was reasonably certain about the items requested. In addition, the IRS properly issued the summons to the bank, which failed to produce the items sought. Finally, the IRS issued the summons for the lawful purpose of conducting a criminal investigation.
K. Davidson, DC Tex.