The Tax Division will handle summons cases involving sensitive or novel issues, including summonses issued to or involving:

1. • attorneys
2. • tax practitioners, as defined in 26 U.S.C. § 7525
3. • any entity operated exclusively for religious purposes (see 26 U.S.C. § 501(c)(3))
4. • the press or members of the news media (see 28 C.F.R. § 50.10 (setting out Department policy regarding obtaining information from, or records of, members of the news media))
5. • tax accrual workpapers
6. • foreign document requests
7. • treaty partners or other matters with international implications
8. • “John Doe” summonses
9. • section 6050I
10. • novel or complex Fifth Amendment claims
11. • computer software and other non-traditional items
12. • state and local agencies and courts
13. • “designated summonses”
14. • consent directives
15. • tax shelter promoters
16. • tax scheme and scam promoters
17. • examinations regarding institution of summons proceedings
18. • examinations into potential liabilities for penalties under 26 U.S.C. §§ 6700, 6701, 6707, and 6708
19. • offshore records
20. • FBAR penalties under 31 U.S.C. § 5314
21. • other unique issues that may arise

The IRS will also refer to the Tax Division petitions to quash foreign document requests issued under 26 U.S.C. § 982. Litigation relating to these requests is similar to summons litigation.
The Tax Division may also refer to the United States Attorney’s Office for handling a summons that the IRS counsel has referred to the Tax Division. See Summons Enforcement Manual, https://www.justice.gov/tax/foia-library .

[updated February 2018]