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Friday, October 9, 2026

Case: Business Entity Is Distinct Person From Agents, Employees for Summons Purposes (4th Cir.) (IRC §7602) - Bloomberg Tax

Under I.R.C. §7602, a business entity is a distinct person from its agents, thus a business cannot quash a summons where a criminal referral has been issued for one of its agents and not the business, the Fourth Circuit Court of Appeals held. The IRS began a civil investigation against a business for overinflating a conservation easement charitable contribution. The accounting firm involved pleaded guilty to conspiring to defraud the United States in regard to the conservation easement tax shelters. Business sought to quash the summons arguing that because its agent was under criminal investigation, it can quash ...

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