IRS Requests to Authorize Grand Jury Investigations

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DOJ Justice Manual › Title 6: Tax › 6-4.000 - Criminal Tax Case Procedures › Justice Manual § 6-4.121

This text was captured on Aug 14, 2026. It is a snapshot, not a live feed, so check the official code before relying on it.

Text

In addition to using administrative process to secure evidence in an investigation, CI also may request that the Tax Division authorize a grand jury investigation when CI either cannot complete its investigation or otherwise determines that it cannot feasibly gather evidence through the administrative process. The IRS's request to authorize a grand jury investigation constitutes a referral of the matter to the Department of Justice. Once a criminal referral is made, the IRS, including CI, may not issue or commence an action to enforce an administrative summons with respect to the taxpayer for the same tax and the same taxable period.

See

26 U.S.C. § 7602(d).

[updated February 2018]

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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IRS Requests to Authorize Grand Jury Investigations · Justice Manual § 6-4.121 | Frix