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ARTICLE · 07 APRIL 2021

District Court Authorizes IRS "John Doe" Summons To Identify U.S. Persons Using Cryptocurrencies

Hogan Lovells Cadwalader
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A federal court in the District of Massachusetts authorized the IRS to serve a "John Doe" summons on a Boston-based "digital currency exchanger" seeking information about as yet unidentified U.S. taxpayers who, from 2016 to 2020.

United StatesFinance and Banking
Jodi Avergun
Jodi Avergun
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A federal court in the District of Massachusetts authorized the IRS to serve a "John Doe" summons on a Boston-based "digital currency exchanger" seeking information about as yet unidentified U.S. taxpayers who, from 2016 to 2020, conducted at least $20,000 in cryptocurrency transactions.

According to the DOJ, the District Court Order allows the IRS to serve the John Doe summons in connection with an investigation of "an ascertainable group or class of persons" where the IRS reasonably believes that such group or class "failed to comply with any provision of any internal revenue laws." The petition does not allege the digital currency exchanger, Circle Internet Financial Inc. and related entities (including Poloniex LLC), engaged in wrongdoing. However, the Court found there is a reasonable basis for the IRS to believe that some of Circle's customers may have violated federal tax laws.

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