In the Matter of the Tax Liabilities of John Does

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

In re TAX LIABILITY OF JOHN DOES. Case No. 21-cv-02201-JCS

ORDER TO SHOW CAUSE WHY

PETITION SHOULD NOT BE DENIED Re: Dkt. No. 1

The United States has filed a petition to authorize service of an Internal Revenue Service (“IRS”) “John Doe” summons to the cryptocurrency exchange Payward Ventures Inc. d/b/a/ Kraken (“Kraken”) and its subsidiaries under 26 U.S.C. § 7609(f), to aid in assessing the potential tax liability of Kraken users. That statute provides as follows:

Any summons described in subsection (c)(1) which does not identify the person with respect to whose liability the summons is issued may be served only after a court proceeding in which the Secretary establishes that— 18 (1) the summons relates to the investigation of a particular person or ascertainable group or class of persons,

(2) there is a reasonable basis for believing that such person or group or class of…