The Internal Revenue Service has long had the power to issue and enforce administrative summonses for the purpose of “ascertaining the correctness of any return … determining the liability of any person for any internal revenue tax … or to collect any such liability.” See Reisman v. Caplin, 375 U.S. 440 (1964). While the courts and the IRS recognized that a taxpayer or an interested party had a right to intervene in an action brought by the IRS to enforce a summons, prior to the 1976 enactment of Internal Revenue Code §7609, there was no legal requirement that notice of a summons be given to a person identified in the summons (other than the summoned person).
TAXLITIGATOR - Tax Controversy (Civil & Criminal) Report 
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