Tiffany Fine Arts, Inc. v. United States

The question presented in this case is whether the Internal Revenue Service (IRS) must comply with the “John Doe” summons procedures of § 7609(f) of the Internal Revenue Code of 1954, 26 U. S. C. § 7609(f), when it serves a summons on a named taxpayer for the dual purpose of investigating both the tax liability of that taxpayer and the tax liabilities of other, unnamed parties.

I

Petitioner Tiffany Fine Arts, Inc., is a holding company for various subsidiaries that promote tax shelters. On October 6,1981, Revenue Agent Joel Lewis issued four summonses to Tiffany, pursuant to 26 U. S. C. §…