Case 3:16-cv-06658-JSC Document 7 Filed 11/30/16 Page 1 of 2

1 CAROLINE D. CIRAOLO
Principal Deputy Assistant Attorney General
2
JEREMY N. HENDON (ORBN 982490)
3
AMY MATCHISON (CABN 217022)
4 Trial Attorneys
United States Department of Justice, Tax Division
5 P.O. Box 683, Ben Franklin Station
Washington, D.C. 20044
6 Telephone:
(202) 353-2466
(202) 307-6422
7
Fax:
(202) 307-0054
8 E-mail: Jeremy.Hendon@usdoj.gov
Amy.T.Matchison@usdoj.gov
9
Western.Taxcivil@usdoj.gov
10 BRIAN J. STRETCH (CABN 163973)
United States Attorney
11
THOMAS MOORE (ALBN 4305-O78T)
12 Chief, Tax Division
COLIN C. SAMPSON (CABN 249784)
13 Assistant United States Attorney
450 Golden Gate Avenue, 11th Floor
14 San Francisco, California 94102
15 Telephone: (415) 436-7020
Email: Colin.Sampson@usdoj.gov
16
Attorneys for United States of America
17
UNITED STATES DISTRICT COURT FOR THE
18
NORTHERN DISTRICT OF CALIFORNIA
19 IN THE MATTER OF THE TAX
LIABILITIES OF:
20
JOHN DOES, United States persons who,
21 at any time during the period January 1, 2013,
through December 31, 2015, conducted
22 transactions in a convertible virtual currency
as defined in IRS Notice 2014-21.
23
24
25
26
27

)
) Civil Number: 3:16-cv-06658-JSC
)
)
) [PROPOSED] ORDER GRANTING
) EX PARTE PETITION FOR LEAVE TO
) SERVE “JOHN DOE” SUMMONS
)
)
)

THIS MATTER is before the Court upon the United States of America’s “Ex Parte Petition for
Leave to Serve “John Doe” Summons” (the “Petition”). Based upon a review of the Petition and
supporting documents, the Court has determined that the “John Doe” summons to Coinbase, Inc. relates
[Proposed] Order Granting Ex Parte Petition
For Leave to Serve John Doe Summons

1

 Case 3:16-cv-06658-JSC Document 7 Filed 11/30/16 Page 2 of 2

1 to the investigation of an ascertainable group or class of persons, that there is a reasonable basis for
2 believing that such group or class of persons has failed or may have failed to comply with any provision
3 of any internal revenue laws, and that the information sought to be obtained from the examination of the
4 records or testimony (and the identities of the persons with respect to whose liability the summons is
5 issued) are not readily available from other sources. It is therefore:
6

ORDERED AND ADJUDGED that the Internal Revenue Service, through Senior Revenue

7 Agent David Utzke or any other authorized officer or agent, may serve an Internal Revenue Service
8 John Doe summons upon Coinbase, Inc. in substantially the form as attached as Exhibit B to Declaration
9 of Senior Revenue Agent David Utzke. A copy of this Order shall be served together with the
10 summons.
IT IS SO ORDERED this 30thday of November

, 2016.

UNIT
ED

United States District
TED
RANJudge

NO

16 Presented by:

RT

17 CAROLINE D. CIRAOLO
Principal Deputy Assistant Attorney General
18
/s/ Jeremy N. Hendon
19
/s/ Amy Matchison
20 JEREMY N. HENDON
AMY MATCHISON
21 Trial Attorneys, Tax Division
U.S. Department of Justice
22

Jud

ER

H

23 BRIAN J. STRETCH
United States Attorney
24 Northern District of California
25 /s/ Colin C. Sampson
COLIN C. SAMPSON
26 Assistant United States Attorney,
Tax Division
27
[Proposed] Order Granting Ex Parte Petition
For Leave to Serve John Doe Summons

G

2

eline S
ge J a c qu

c ot t C o

rley

R NIA

15

LI

14

FO

13

S DISTRICT
E
T
C
TA

RT
U
O

S

12

A

11

N

F
D IS T IC T O
R

C