Viewtech, Inc. v. United States

OPINION

IKUTA, Circuit Judge:

In connection with an assessment of a taxpayer for unpaid taxes, the IRS began searching for the taxpayer’s assets and issued a summons to a bank for a related third party’s account information. The taxpayer and third party argue that 26 U.S.C. § 7609 1 required the IRS to notify them, which would have enabled them to seek a court order quashing the summons. Applying Ip v. United States, 205 F.3d 1168 (9th Cir.2000), we conclude that under the circumstances of this case, no notice was necessary, and therefore we affirm the district court.

I

After the IRS assessed…