How it works
A John Doe summons is a court-approved IRS demand to a third party for records on a class of unnamed people who may have failed to comply with tax law. The IRS has served them on Coinbase (2016), Kraken (2021), Circle and Poloniex (2021), and others, typically for customers who transacted above a dollar threshold. Returns include identities, transaction histories, and wallet addresses.
Why it matters
The IRS has argued under Section 7609(e)(2) that the assessment statute of limitations is suspended while a summons is pending, which can reopen years taxpayers assumed were closed. Letters to Poloniex users in 2025 and 2026 referenced tax years back to 2016.
Example
A Poloniex customer who traded in 2017 and never reported it receives an IRS letter in 2026. The IRS position is that the 2017 year remained open because the summons tolled the clock.
Related: Section 7609 tolling, assessment statute of limitations. Read more: why Poloniex years are still open.
