On 18 May 2023, the Supreme Court sided with the IRS in a dispute that centered on the agency’s power to issue summons for bank account records without notice to the interested account holders. The court’s decision, however, is far from an unmitigated victory for the agency. In fact, the majority and concurring opinions reflect the court has significant reservations about the IRS’s use of no-notice summons, particularly in cases involving innocent third parties.