Whether the federal Right to Financial Privacy Act was fully preempted by the Internal Revenue Code, resulting in the production of financial information of persons and business entities who did not receive notice of the summonses

QUESTION PRESENTED Whether, by holding that the federal Right to Financial Privacy Act was fully preempted by the Internal Revenue Code despite the Tenth Circuit’s decision to the contrary, the Eleventh Circuit erroneously upheld the issuance of United States’ summonses to a third party that only notified the taxpayers under investigation instead of all the taxpayers possessing an interest in the accounts, which resulted in the production of financial information of persons and business entities who did not receive notice of the summonses. 1