Presley v. United States, No. 17-10182 (11th Cir. 2018)Annotate this Case
The Eleventh Circuit affirmed the district court's order denying the quashing of IRS summonses to Bank of America in the course of investigating the federal income tax liabilities of a lawyer, his law firm, and associated parties (plaintiffs). The court held that neither plaintiffs nor their law firm clients whose interests plaintiffs attempted to invoke have a viable Fourth Amendment objection to the IRS's collection of plaintiffs' bank records from plaintiffs' bank. Plaintiffs' arguments were foreclosed by the Supreme Court's holdings in United States v. Miller, 425 U.S. 435 (1976), and United States v. Powell, 379 U.S. 48 (1964).