Opinion of the Court
to “determin[e] the liability” of a taxpayer or “any transferee or fiduciary” for unpaid taxes. 26 U. S. C. §7602(a). The IRS also may serve a summons to “collec[t] any such liability.” Ibid. These summonses can extend to third parties beyond the taxpayer under investigation. Tiffany Fine Arts, Inc. v. United States, 469 U. S. 310, 315–316 (1985). Accordingly, the IRS may request the production of “books, papers, records, or other data” from “any person” who possesses information concerning a delinquent taxpayer. §7602(a)(2).
Given the breadth of this power, Congress has imposed certain safeguards. The IRS must generally give “notice of the summons” to “any person … identified in the summons.” §7609(a)(1). Anyone entitled to notice can bring a motion to quash the summons. §7609(b)(2)(A). And the Internal Revenue Code provides district courts with “jurisdiction to hear and determine any proceeding” concerning a motion to quash, §7609(h)(1), thereby waiving the sovereign immunity of the United States, see FAA v. Cooper, 566 U. S. 284, 290 (2012).
There are, however, exceptions to the notice requirement. As relevant, the IRS need not provide notice to a person “who is identified in the summons,” §7609(a)(1), if the summons is:
“issued in aid of the collection of—
“(i) an assessment made or judgment rendered against the person with respect to whose liability the summons is issued; or
“(ii) the liability at law or in equity of any transferee or fiduciary of any person referred to in clause (i).” §7609(c)(2)(D)
In other words, the IRS may issue summonses both to determine whether a taxpayer owes money and later to collect any outstanding liability. When the IRS conducts an investigation for the purpose of “determining the liability” of a
