In the Matter of the Tax Liabilities of: John Does, et al.
Filing
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ORDER ALLOWING IRS TO SERVE "JOHN DOE" SUMMONSES re 1 Petition to Enforce IRS Summons filed by United States of America, ***Civil Case Terminated.. Signed by Judge Yvonne Gonzalez Rogers on 8/29/13. (fs, COURT STAFF) (Filed on 8/29/2013)
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IN THE UNITED STATES DISTRICT COURT FOR THE
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NORTHERN DISTRICT OF CALIFORNIA
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IN THE MATTER OF THE TAX LIABILITIES )
OF:
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JOHN DOES, Norwegian taxpayers holding
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Wells Fargo Bank, N.A. payment cards
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XXXXXXXXXXXX5101,
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XXXXXXXXXXXX5019,
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XXXXXXXXXXXX1025; Mechanics Bank
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payment card XXXXXXXXXXXX3543; and
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JPMorgan Chase & Co. payment card
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XXXXXXXXXXXX7637
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________________________________________ )
Case No. CV-13-3393 YGR
ORDER ALLOWING IRS
TO SERVE “JOHN DOE” SUMMONSES
THIS MATTER is before the Court upon the United States of America’s Ex Parte Petition for
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Leave to Serve “John Doe” Internal Revenue Service summonses. Based upon a review of the
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Petition, supporting memorandum, and declarations (with exhibits thereto), the Court has determined
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that the “John Doe” summonses to Wells Fargo Bank, N.A., Mechanics Bank, and JPMorgan Chase &
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Co. relate to the investigation of particular persons or groups or classes of persons, that there is a
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reasonable basis for believing that such persons or groups or classes of persons may fail or may have
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failed to comply with the internal revenue laws of Norway, and that the information sought to be
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obtained from the examination of the records or testimony (and the identities of the persons with
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respect to whose liability the summonses are issued) are not readily available from other sources. It
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is, therefore–
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ORDERED AND ADJUDGED that the Internal Revenue Service, through Revenue Agent
ORDER RE “JOHN DOE” IRS SUMMONSES
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Cheryl Kiger or any other authorized officer or agent, may serve Internal Revenue Service “John
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Doe” summonses upon Wells Fargo Bank, N.A., Mechanics Bank, and JPMorgan Chase & Co. in
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substantially the form as attached as Exhibits A, B, and C to the Declaration of Revenue Agent Cheryl
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Kiger, with the following agreed modifications:
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1.
Paragraph 1 of the Attachment to the “John Doe” Summons to Wells Fargo Bank,
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N.A. shall be amended so that the documents sought for the client holding payment
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card account number xxxxxxxxxxxx5101 shall be for the period October 2004
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through April 2009.
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2.
Paragraph 2 of the Attachment to the “John Doe” Summons to Wells Fargo Bank,
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N.A. shall be amended so that the documents sought for the client holding payment
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card account number xxxxxxxxxxxx5109 shall be for the period January 2003
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through January 2008.
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3.
Paragraph 3 of the Attachment to the “John Doe” Summons to Wells Fargo Bank,
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N.A. shall be amended so that the documents sought for the client holding payment
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card account number xxxxxxxxxxxx1025 shall be for the period May 2005 through
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January 2009.
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4.
Paragraph 1 of the Attachment to the “John Doe” Summons to Mechanics Bank shall
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be amended so that the documents sought for the client holding payment card account
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number xxxxxxxxxxxx3543 shall be for the period April 2003 through April 2006.
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5.
Paragraph 1 of the Attachment to “John Doe” Summons to JPMorgan Chase & Co.
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shall be amended so that the documents sought for the client holding payment card
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account number xxxxxxxxxxxx7637 shall be for the period January 2003 through
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January 2006.
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DONE AND ORDERED this ___ day of ________, 2013.
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August
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_______________________________
UNITED STATES DISTRICT JUDGE
YVONNE GONZALEZ ROGERS
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ORDER RE “JOHN DOE” IRS SUMMONSES
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