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Issue(s): Whether the exception in I.R.C. \\xa7 7609(c)(2)(D)(i) to the notice requirements for an Internal Revenue Service summons on third-party recordkeepers applies only when the delinquent taxpayer owns or has a legal interest in the summonsed records, as the U.S. Court of Appeals for the 9th Circuit has held, or whether the exception applies to a summons for anyone\\u2019s records whenever the IRS thinks that person\\u2019s records might somehow help it collect a delinquent taxpayer\\u2019s liability, as the U.S. Courts of Appeals for the 6th and 7th Circuits have held.