11th Circuit Affirms Another Victory for IRS on Peruvian Tax Request

On December 4, 2023, the Eleventh Circuit Court of Appeals affirmed the dismissal of three petitions by siblings to quash IRS summonses issued for their bank records at the request of Peruvian authorities.  The appellate court in a per curiam decision found that the court did not err in denying an evidentiary hearing with respect to bad faith by the requesting Peruvian government and properly refused to hold a hearing.