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Rh to speak, to do with as it will in the collection arena. Thus, in my view, courts must not interpret §7609(c)(2)(D)(i) as if that agency has been gifted with boundless authority. Treating the IRS’s power to issue unnoticed summonses as effectively unlimited permits the exception to devour the rule, upsetting the statute’s calibration.

Second, and similarly, it is hard for me to believe that, in the context of a default-notice system, Congress would intentionally insert an exception that could so dramatically upend its objectives. Read too broadly, §7609(c)(2)(D)(i) would presumably permit the IRS to summon anyone’s records without notice, no matter how broad the summons is or how potentially intrusive that records request might be, so long as the agency thinks doing so would provide a clue to the location of a delinquent taxpayer’s assets.

Imagine, for example, a delinquent taxpayer who routinely visits his local mom-and-pop dry cleaning business. Imagine also that the IRS suspects this delinquent taxpayer sometimes uses credit cards with different names. Under a broad reading of §7609(c)(2)(D)(i), I suppose the IRS could issue a summons to the dry cleaner’s bank without notice to the dry cleaner, seeking years of the dry cleaner’s financial records. The agency might believe that having the entirety of that business’s financial information would aid its tax-collection efforts—even though the taxpayer has no known financial interest in that business, or any special relationship with the business’s owners—because knowing what methods of payment (or aliases) the taxpayer regularly uses could help the agency track down the taxpayer’s assets. And it might intend to sift through the requested haystack of the business’s bank records in order to find the needle of the taxpayer’s transaction information.

For their part, the dry cleaner’s owners would probably look askance at having all of their financial records requisitioned and reviewed in this manner. But, without notice,