A recent challenge by a taxpayer to the Internal Revenue Service’s seizure of the taxpayer’s cryptocurrency records can proceed in the face of an IRS motion to dismiss, based on a new federal appeals court decision.
A Bloomberg Law article explains that a novel legal theory may be a promising avenue to pursue for those whose personal financial information is sought or obtained by the IRS from a virtual currency exchange and may also prove to be a useful strategy for the exchanges themselves to resist John Doe summonses.
The article was authored by litigation & enforcement partner Helen Gugel, tax & benefits partner Loretta Richard, litigation & enforcement counsel Mark Cianci.
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