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John Doe Intervenes in Virtual Currency Summons Enforcement Case

The Internal Revenue Service (IRS) has broad authority under Internal Revenue Code (IRC) Section 7602 to issue administrative summonses to taxpayers and third parties to gather information to ascertain the correctness of any return. If the IRS does not know the identity of the parties whose records are covered by the summons, the IRS may issue a “John Doe” summons only upon receipt of a court order. The court will issue the order if the IRS has satisfied the three criteria provided in IRC Section 7609(f):

  • The summons relates to the investigation of a particular person or ascertainable group or class of persons,
  • There is a reasonable basis for believing that such person or group or class of persons may fail or may have failed to comply with any provision of any internal revenue law, and
  • The information sought to be obtained from the examination of the records (and the identity of the person or persons with respect to whose liability the summons is issued) is not readily available from other sources.


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IRS Adds More Enforcement Employees

In an internal memo to agency employees, Internal Revenue Service (IRS) Commissioner John A. Koskinen announced the IRS’s intention to hire between 600 and 700 enforcement personnel.  It is estimated that between 2010 and the end of 2016, the IRS will have lost more than 17,000 employees, 5,000 from the enforcement area.  The hiring, which is to occur in two waves, should fill key gaps in the IRS’s enforcement workforce created by years of attrition.  This will be the IRS’s first significant enforcement hiring in more than five years.

Whether an increase in enforcement personnel will change the trend of a lax IRS remains to be seen.  Taxpayers, however, should pay close attention to how this increase in IRS personnel affects the audit of their returns and the level of depth of an IRS examination.  Stay tuned!

More details can be found at:

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