> (c) (2) This section shall not apply to any summons (D) issued in aid of the collection of (i) an assessment made or judgment rendered against the person with respect to whose liability the summons is issued; or (ii) the liability at law or in equity of any transferee or fiduciary of any person referred to in clause (i)
(I am not your lawyer, this is not legal advice, this is not an opinion, this is just a citation.)
https://www.law.cornell.edu/uscode/text/26/7609
And here is (c) (2) (D):
> (c) (2) This section shall not apply to any summons (D) issued in aid of the collection of (i) an assessment made or judgment rendered against the person with respect to whose liability the summons is issued; or (ii) the liability at law or in equity of any transferee or fiduciary of any person referred to in clause (i)
(I am not your lawyer, this is not legal advice, this is not an opinion, this is just a citation.)