Document Type



The IRS is authorized, by the use of an administrative summons, to thoroughly inspect a taxpayer's business and financial background. Although the taxpayer's attorney may feel powerless to restrict this free flow of information, there are defined limitations to the use of an administrative summons. These limitations are designed to abrogate its abuse by the IRS. This comment provides a summary of the limitations of an administrative summons, case law interpretation of the requirements for its issuance, and practical considerations for the protection of the taxpayer's financial privacy.