Glossary

IRC Section 7609 (summons tolling)

Section 7609 governs third-party IRS summonses, and subsection (e)(2) pauses the statute of limitations on assessment when a summoned third party, such as an exchange, does not fully respond within six months.

How it works

Section 7609 governs IRS summonses to third parties. Under subsection (e)(2), when a summoned third party does not fully respond within six months, the assessment and collection statutes of limitations for the taxpayers whose records were summoned are suspended until the response is complete. The IRS has invoked this for John Doe summonses to crypto exchanges.

Why it matters

A taxpayer who assumes 2017 is closed may be wrong if their exchange was summoned and responded slowly. Letters to Poloniex users in 2025 and 2026 rested on this argument.

Related: John Doe summons, assessment statute. Read more: summons tolling and Poloniex.

Guides that cover iRC Section 7609

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Definitions are general information, not legal advice, and may not reflect the most recent changes in law.

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