With a normal summons, the IRS seeks information about a specific taxpayer whose identity it knows.

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Now, under the current Tax Code, Section 6103 limits disclosure of taxpayer information except under specific circumstances.

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While declining to comment on any specific cases, banks or countries, Keneally ticked off several reasons why a taxpayer might be disqualified from the program after originally being accepted, including a failure to cooperate or a failure to alert the U.S. government (as required by law) that he or she was contesting a foreign summons.

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