United States of America and Joel Cohen, Revenue Officer of the Internal Revenue Service v. Zulema Bichara

The district court found that service of an Internal Revenue Service (“IRS”) summons by leaving it at appellee Bichara’s “last and usual place of abode” violated the minimum due process requirements of the Constitution and consequently that the government’s petition to enforce the summons should be dismissed. Because this determination was erroneous, we reverse.

Joel Cohen, a revenue officer for the IRS, was conducting an investigation into the tax liabilities of Zulema Bichara. Pursuant to § 7602 of the Code, 26 U.S.C. § 7602, Cohen issued a summons to Bichara directing that she appear before…