CA6: When target of an IRS summons is named, it’s not a “John Doe summons”

“There is no shortage of reasons to reject Byers’s argument. But her argument, we acknowledge, has intuitive appeal—‘Shouldn’t the government have to give a reason why it wants my information?’—and merits this fulsome response. In all, Byers has raised a colorable policy argument, but not a legal one. ‘Simply stated, the IRS is not required to comply with the “John Doe summons” requirements, where the summons relates to an investigation of a named party.’ 35 Am. Jur. 2d Federal Tax Enforcement § 55. The district court did not err in rejecting Byers’s argument.” Byers v. United States, IRS, 2020 U.S. App. LEXIS 20014 (6th Cir. June 26, 2020).

Defendant’s cell phone seizure and search warrant claim depended on the legality of his arrest. Since the arrest was with probable cause, the seizure of the phone was valid. United States v. Hester, 2020 U.S. Dist. LEXIS 113055 (S.D.N.Y. June 26, 2020).*