As referenced in this judgment, here is 26 U.S. Code § 7609 "Special procedures for third-party summonses": https://www.law.cornell.edu/uscode/text/26/7609 htt

As referenced in this judgment, here is 26 U.S. Code § 7609 "Special procedures for third-party summonses": https://www.law.cornell.edu/uscode/text/26/7609 https://www.law.cornell.edu/uscode/text/26/7609 And here is (c) (2) (D): > (c) (2) This section shall not apply to any summons (D) 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) (I am not your lawyer, this is not legal advice, this is not an opinion, this is just a citation.)