On November 12th, 2013 the United States District Court for the Southern District of Texas issued a decision in Trowbridge v. Internal Revenue Service (Civil Action No. 4:13-cv-1850, Nov. 12, 2013). The case involved the notice requirement for I.R.S. summonses to third parties under § 7609. Typically, the IRS must provide notice to the subject of an audit when an administrative summons is issued to a third party. The Service can forgo such notice, however, when the third party is an employee of the audited taxpayer. In Trowbridge, the taxpayer attempted to quash a summons for testimony and documents issued to one of his employees. The Court found that the taxpayer was not entitled to notice, and had no standing to challenge the summons.