Jodi Hohman v. Maurice Eadie

MERRITT, Circuit Judge.

This appeal raises a highly technical issue arising from a potential conflict between the Internal Revenue Code and the Federal Right to Financial Privacy Act of 1978, 12 U.S.C. §§ 3401 - 3422. The IRS issued two "John Doe" summonses without first obtaining approval in a federal district court as required by the Internal Revenue Code ("Code"), see I.R.C. § 7609(f). The IRS served the summonses on Chase Bank to obtain financial records relating to two limited liability companies ("LLCs"). Plaintiffs, the LLCs and subjects of the John Doe summonses, alleged that the IRS's…