2 . This determination is also called a “Statutory Notice of Deficiency.” 3 . Accordingly, this Court does not reach Petitioners’ additional arguments in their petition to quash. 4 . Petitioners also filed the identical sur-reply a week later. (R. 40.) 5 . In fact, Greisman, as a third party to the IRS's investigation of Petitioners, may deserve even greater protection against a burdensome summons. See United States v. Bisceglia, 420 U.S. 141, 157, 95 S.Ct. 915, 43 L.Ed.2d 88 (1975) (Stewart, J., Douglas, J. dissenting) (stating that "federal courts have always scrutinized with particular care any IRS summons directed to a 'third party,’ i.e., to a party other than the taxpayer under investigation.”); see also United States v. Monumental Life Ins. Co., 440 F.3d 729, 735 (6th Cir.2006) (<HOLDING>). 6 . In its in camera filing, the government
holding that third party to irss investigation deserved greater protection against burdensome summons holding defendant assumed risk that third party would consent to search of storage locker where defendant instructed third party to rent locker under third partys name and allowed third party to keep possession of lease papers and to occasionally retain the keys holding principal liable to third party for tort of agent despite lack of privity between principal and third party holding that a third party holding legal title to property is a necessary party in an action for equitable distribution holding that a third party has authority to consent to a search if the third party is a coinhabitant