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United States v. Coinbase

United States District Court for the Northern District of California

120 A.F.T.R. 2d 2017-6671 (2017)

Facts

Coinbase, Inc. (defendant) was a virtual-currency exchange that handled most of the bitcoin transactions in the United States. Although Coinbase served almost six million customers and handled six billion transactions, only 900 taxpayers had filed income-tax returns listing bitcoin as property. The Internal Revenue Service (IRS) (plaintiff) believed that Coinbase users were regularly failing to report their taxable gains related to bitcoin transactions. The IRS served a summons on Coinbase seeking information about most of Coinbase’s customers, including account-opening records, correspondence between Coinbase and account owners, Know-Your-Customer due-diligence records, copies of licenses or passports, wallet addresses, transaction logs, account statements, and public keys for wallets. Coinbase failed to comply, and the IRS petitioned to enforce the summons. While petitioning, the IRS narrowed its summons to request information for just 10,000 of Coinbase’s customers.

Rule of Law

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Issue

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Holding and Reasoning (Corley, J.)

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A "yes" or "no" answer to the question framed in the issue section;
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