Syllabus

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.

SUPREME COURT OF THE UNITED STATES

Syllabus

POLSELLI ET AL. v. INTERNAL REVENUE SERVICE CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

No. 21–1599. Argued March 29, 2023—Decided May 18, 2023 The Internal Revenue Service has the power to issue summonses to pur- sue unpaid federal taxes and the people who owe them. When the IRS issues a summons, it must generally provide notice to any person iden- tified in the summons, §7609(a)(1). Anyone entitled to such notice may then bring a motion to quash the summons, §7609(b)(2)(A). But when the IRS issues a summons “in aid of the collection of . . . an assessment made . . . against the person