Opinion of the Court
Notice: This opinion is subject to formal revision before publication in the preliminary print of the United States Reports. Readers are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, of any typographical or other formal errors, in order that corrections may be made before the preliminary print goes to press.
SUPREME COURT OF THE UNITED STATES
No. 21–1599
HANNA KARCHO POLSELLI, ET AL., PETITIONERS v. INTERNAL REVENUE SERVICE
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT
[May 18, 2023]
Chief Justice Roberts delivered the opinion of the Court.
For as long as Americans have had to pay taxes, at least some have tried to avoid them. And for as long as Americans have avoided taxes, the Internal Revenue Service and its predecessors have tried to collect them. As an old joke goes: “I believe we should all pay taxes with a smile. I tried but they wanted cash.”
Congress has given the IRS considerable power to go after unpaid taxes. One tool at the Service’s disposal is the authority to summon people with information concerning a delinquent taxpayer. But to safeguard privacy, the IRS is generally required to provide notice to anyone named in a summons, who can then sue to quash it. Today’s case concerns an exception to that general rule.
I
To pursue unpaid taxes and the people who owe them, “Congress has granted the Service broad latitude to issue summonses.” United States v. Clarke, 573 U. S. 248, 250 (2014). Among other things, the IRS may issue a summons
