Page:Polselli v. IRS.pdf/1

(Slip Opinion)

(a) The statute sets forth three conditions to exempt the IRS from providing notice in circumstances like these. First, a summons must be “issued in aid of … collection,” §7609(c)(2)(D). Second, it must aid the collection of “an assessment made or judgment rendered,” §7609(c)(2)(D)(i). Third, a summons must aid the collection of assessments or judgments “against the person with respect to whose liability