Opinion of the Court
general notice requirement, but also of the specific exception the statute provides.
We do not dismiss any apprehension about the scope of the IRS’s authority to issue summonses. As we have said, “the authority vested in tax collectors may be abused, as all power is subject to abuse.” Bisceglia, 420 U. S., at 146. Tax investigations often involve the pursuit of sensitive records. In this case, for instance, the IRS sought information from law firms concerning client accounts. And even the Government concedes that the phrase “in aid of the collection” is not “limitless.” Tr. of Oral Arg. 33. The Government proposes a test turning on reasonableness: So long as a summons is “reasonably calculated to assisting in collection,” it can fairly be characterized as being issued “in aid of” that collection. Id., at 26; see also id., at 36 (“[T]he third party should have some financial ties or ha[ve] engaged in financial transactions with the delinquent taxpayer.”).
This is not, however, the case to try to define the precise bounds of the phrase “in aid of the collection.” The parties did not argue, and the panel below did not decide, the contours of that phrase. See Illinois v. Gates, 462 U. S. 213, 222–223 (1983). In addition, both the briefing by the parties and the question presented focus only on whether the exception provided in §7609(c)(2)(D)(i) requires that a taxpayer maintain a legal interest in records summoned by the IRS. For the reasons we have given, the answer is no.
The judgment of the Court of Appeals for the Sixth Circuit is affirmed.
