Victor Jaramillo Moderates Panel on John Doe Summonses and Crypto Compliance Gap at ABA Fall Tax Meeting

A John Doe summons allows the IRS, with court approval, to obtain information from a third-party about a class of taxpayers. The IRS’s use of these summonses to identify account holders of UBS made headlines in 2008. Since then, the IRS has expanded the use of John Doe summonses as an available investigatory tool, including on domestic cryptocurrency exchanges. This panel will recount the historical use of John Doe summonses by the IRS; examine areas in which the IRS is currently employing these summonses and where they can be used in the future, and discuss important privilege issues they may raise, an example of which is currently pending before the U.S. Supreme Court in Taylor Lohmeyer Law Firm v. United States (Docket 20-1596).