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IRS Criminal Tax Cases
Administrative Summonses
Most IRS criminal investigations are conducted by Special Agents with the Criminal Investigation Division of the IRS. The principle means by which these agents obtain documents and records for their investigation is by the Administrative Summons. These summonses are usually directed to third-parties, but they are also used to obtain documents directly from the target of the investigation. The Internal Revenue Code (Sec. 7602, et seq.) authorizes the use of the Administrative Summons, but also provides the manner and means by which either a third-party or the taxpayer can move to have the summons quashed.