IRS’s “John Doe” Summons Procedure to Obtain Taxpayers’ Coinbase Account Information Is Constitutional (D.N.H.) (IRC §7609)

IRS’s utilization of its “John Doe” summons procedure to obtain a taxpayer’s account information from Coinbase, a virtual currency exchange is constitutional, a district court held, granting the government’s motion to dismiss. Some of the records it collected belonged to Taxpayer, who bought and sold bitcoin through Coinbase. Taxpayer doesn’t have protectable Fourth or Fifth Amendment interests in the records produced by Coinbase in response to the John Doe summons. Even assuming that he did, the IRS’s actions satisfied the Fourth Amendment ‘s reasonableness requirement and provided him constitutionally adequate process under the Due Process Clause. Regarding his statutory claim …