Opinion of the Court
issued.” §7609(c)(2)(D)(i). Clause (ii), in contrast, concerns the liability of a “transferee or fiduciary.” §7609(c)(2)(D)(ii). That the notice exception distinguishes between taxpayers and their fiduciaries or transferees should come as no surprise. The Code elsewhere separately empowers the IRS to collect outstanding tax liabilities from taxpayers, on the one hand, and from transferees or fiduciaries, on the other. See §6901. The Code also differentiates between taxpayers and their fiduciaries or transferees in empowering the IRS to issue summonses in the first place. See §7602(a).
These distinctions—between liability and assessment or judgment, and between taxpayers and their transferees or fiduciaries—are not just academic. They show that the second notice exception found in clause (ii) applies in situations where clause (i) may not. To dispense with notice, clause (i) requires that there be “an assessment made or judgment rendered against the person with respect to whose liability the summons is issued.” §7609(c)(2)(D)(i). By contrast, clause (ii) does not impose the same conditions. It instead authorizes the IRS to issue a summons in aid of collecting a “liability at law or in equity,” and refers specifically to the liability of any “transferee or fiduciary” of the delinquent taxpayer. §7609(c)(2)(D)(ii). As a result, clause (ii) permits the IRS to issue unnoticed summonses to aid its collection from transferees or fiduciaries before it makes an “official recording of a taxpayer’s liability.” Direct Marketing Assn., 575 U. S., at 9. “That may not be very heavy work for the phrase to perform, but a job is a job, and enough to bar the rule against redundancy from disqualifying an otherwise sensible reading.” Gutierrez v. Ada, 528 U. S. 250, 258 (2000); see also Nielson v. Preap, 586 U. S. ___, ___ (2019) (slip op., at 21) (a clause that “still has work to do” is not superfluous).
Clause (ii) addresses an additional potential problem as well. Delinquent taxpayers sometimes declare bankruptcy
