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TIFFANY FINE ARTS, INC. v. UNITED STATES

No. 83-1007.

469 U.S. 310 (1985)

105 S.Ct. 725

83 L.Ed.2d 678

TIFFANY FINE ARTS, INC., ET AL. v. UNITED STATES ET AL.

Supreme Court of United States.

Decided January 9, 1985.

Attorney(s) appearing for the Case

Michael D. Savage argued the cause for petitioners. With him on the brief was David M. Rubin.

Deputy Solicitor General Wallace argued the cause for respondents. With him on the brief were Assistant Attorney General Archer, Charles E. Brookhart, and William A. Whitledge.*

JUSTICE MARSHALL delivered the opinion of the Court.

The question presented in this case is whether the Internal Revenue Service (IRS) must comply with the "John Doe" summons procedures of § 7609(f) of the Internal Revenue Code of 1954, 26 U. S. C. § 7609(f), when it serves a summons on a named taxpayer for the dual purpose of investigating both the tax liability of that taxpayer and the tax liabilities of other, unnamed parties.

I

Petitioner...

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