Opinion of the Court
or otherwise discharge debt. When they do so, the Government may not be able to collect “an assessment made or judgment rendered against the” taxpayer. §7609(c)(2)(D)(i). In those situations, clause (i) may not apply, for a summons cannot be “issued in aid of” an impossible collection effort. §7609(c)(2)(D). But clause (ii) may nevertheless permit the IRS to issue unnoticed summonses to collect the “liability” of the taxpayer’s transferee or fiduciary. §7609(c)(2)(D)(ii).
IV
Petitioners also emphasize the privacy concerns that led Congress to enact the notice requirement in the first place. They highlight that “Congress enacted §7609 in response to two decisions in which we gave a broad construction to the IRS’s general summons power.” Tiffany Fine Arts, 469 U. S., at 314. In Donaldson v. United States, 400 U. S. 517 (1971), we considered whether the employee of a company to which the IRS had issued a summons could intervene to prevent his employer’s compliance with the Service’s request. Id., at 527. We concluded that the employee had no right to do so. Id., at 530. And in United States v. Bisceglia, 420 U. S. 141 (1975), we approved an IRS summons issued to a bank “for the purpose of identifying an unnamed individual who had deposited a large amount of money in severely deteriorated bills,” concluding that the IRS had not abused its authority. Tiffany Fine Arts, 469 U. S., at 315 (characterizing Bisceglia).
Donaldson and Bisceglia help explain why Congress enacted §7609, which establishes a baseline rule requiring the IRS to provide notice and which authorizes anyone entitled to notice to move to quash a summons. §7609(a). But neither case obliges us to read the notice exception in §7609(c)(2)(D)(i) more narrowly than its terms provide. We think the history highlighted by petitioners supports a contrary conclusion. That Congress proved acutely aware of our prior decisions supports a plain reading not only of the
