Case: Suit to Enjoin Summons for Cryptocurrency Information Not Barred By Anti-Injuction Act (1st Cir.) (IRC §7609)

Suit to enjoin the IRS from using information obtained from third-party summons regarding his cryptocurrency can proceed, the First Circuit Court of Appeals held. Taxpayer engaged in cryptocurrency transactions and claimed to properly account for such transactions. The IRS investigated a cryptocurrency institution and issued summonses for information on its clients. The IRS notified Taxpayer that it believe he improperly reported his cryptocurrency transactions. Taxpayer sued arguing violation of Constitutional rights and I.R.C. §7609(f) on John Doe summonses. The district court dismissed the case under the Anti-Injunction Act. Taxpayer appealed. The IRS’s summons activities clearly fall within the category …