About Course

This two-hour continuing education course provides tax professionals with a technical, practice-ready framework for representing clients in connection with IRS summonses, third-party record-keeper summonses, third-party contact notices, and taxpayer interviews. This topic does not overlap with any existing course in the current catalog, and the course builds the full framework from the IRS’s underlying summons authority through the specific procedural protections available to taxpayers and third parties.

Apply IRC Section 7602 to identify the scope of the IRS's summons authority and the categories of summons a practitioner may encounter
Apply the four-factor standard from United States v. Powell governing judicial enforcement of a summons
Apply IRC Section 7609 to identify a taxpayer's notice rights and the 20-day deadline to institute a proceeding to quash a third-party summons
Identify the special judicial approval procedure required for a John Doe summons and the categories of summonses exempted from Section 7609 notice
Apply IRC Section 7602(c), as amended by the Taxpayer First Act of 2019, to the advance notice required before third-party contact, including the reprisal exception
Apply IRC Section 7521 to identify a taxpayer's rights during an IRS interview, including the right to representation and to record the interview
Apply practical strategy for evaluating whether to comply with, negotiate, or formally challenge a summons or third-party contact notice

Course Content

Module 1 – Summons Authority — Section 7602 and the Powell Standard
Summons Authority — Section 7602 and the Powell Standard

Summons Authority — Section 7602 and the Powell Standard

Module 2 – Third-Party Record-Keeper Summonses — Section 7609 Notice, Intervention, and John Doe Summonses
Third-Party Record-Keeper Summonses — Section 7609 Notice, Intervention, and John Doe Summonses

Module 3 – Third-Party Contact Notice Under Section 7602(c)
Third-Party Contact Notice Under Section 7602(c)

Module 4 – Taxpayer Interview Rights, Representation, and Practical Strategy
Taxpayer Interview Rights, Representation, and Practical Strategy

Final Assessment – IRS Summonses, Interviews, and Third-Party Contact Procedures
This final assessment consists of 10 multiple-choice questions covering all four modules of this course. A passing score of 70% or better is required.

IRS Summonses, Interviews, and Third-Party Contact Procedures

About Course

What Will You Learn?

Course Content

Module 1 – Summons Authority — Section 7602 and the Powell Standard
<p>Summons Authority — Section 7602 and the Powell Standard</p>

Summons Authority — Section 7602 and the Powell Standard

Module 2 – Third-Party Record-Keeper Summonses — Section 7609 Notice, Intervention, and John Doe Summonses
<p>Third-Party Record-Keeper Summonses — Section 7609 Notice, Intervention, and John Doe Summonses</p>

Third-Party Record-Keeper Summonses — Section 7609 Notice, Intervention, and John Doe Summonses

Module 3 – Third-Party Contact Notice Under Section 7602(c)
<p>Third-Party Contact Notice Under Section 7602(c)</p>

Third-Party Contact Notice Under Section 7602(c)

Module 4 – Taxpayer Interview Rights, Representation, and Practical Strategy
<p>Taxpayer Interview Rights, Representation, and Practical Strategy</p>

Taxpayer Interview Rights, Representation, and Practical Strategy

Final Assessment – IRS Summonses, Interviews, and Third-Party Contact Procedures
This final assessment consists of 10 multiple-choice questions covering all four modules of this course. A passing score of 70% or better is required.

IRS Summonses, Interviews, and Third-Party Contact Procedures

About Course

Related Courses

What Will You Learn?

Course Content

Module 1 – Summons Authority — Section 7602 and the Powell Standard <p>Summons Authority — Section 7602 and the Powell Standard</p>

Summons Authority — Section 7602 and the Powell Standard

Module 2 – Third-Party Record-Keeper Summonses — Section 7609 Notice, Intervention, and John Doe Summonses <p>Third-Party Record-Keeper Summonses — Section 7609 Notice, Intervention, and John Doe Summonses</p>

Third-Party Record-Keeper Summonses — Section 7609 Notice, Intervention, and John Doe Summonses

Module 3 – Third-Party Contact Notice Under Section 7602(c) <p>Third-Party Contact Notice Under Section 7602(c)</p>

Third-Party Contact Notice Under Section 7602(c)

Module 4 – Taxpayer Interview Rights, Representation, and Practical Strategy <p>Taxpayer Interview Rights, Representation, and Practical Strategy</p>

Taxpayer Interview Rights, Representation, and Practical Strategy

Final Assessment – IRS Summonses, Interviews, and Third-Party Contact Procedures This final assessment consists of 10 multiple-choice questions covering all four modules of this course. A passing score of 70% or better is required.

IRS Summonses, Interviews, and Third-Party Contact Procedures

Module 1 – Summons Authority — Section 7602 and the Powell Standard
<p>Summons Authority — Section 7602 and the Powell Standard</p>

Module 2 – Third-Party Record-Keeper Summonses — Section 7609 Notice, Intervention, and John Doe Summonses
<p>Third-Party Record-Keeper Summonses — Section 7609 Notice, Intervention, and John Doe Summonses</p>

Module 3 – Third-Party Contact Notice Under Section 7602(c)
<p>Third-Party Contact Notice Under Section 7602(c)</p>

Module 4 – Taxpayer Interview Rights, Representation, and Practical Strategy
<p>Taxpayer Interview Rights, Representation, and Practical Strategy</p>

Final Assessment – IRS Summonses, Interviews, and Third-Party Contact Procedures
This final assessment consists of 10 multiple-choice questions covering all four modules of this course. A passing score of 70% or better is required.