In the Matter of the Tax Liabilities of: John Does, et al.

Filing 9

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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1 2 3 4 5 6 7 8 IN THE UNITED STATES DISTRICT COURT FOR THE 9 NORTHERN DISTRICT OF CALIFORNIA 10 11 12 13 14 15 16 17 IN THE MATTER OF THE TAX LIABILITIES ) OF: ) ) JOHN DOES, Norwegian taxpayers holding ) Wells Fargo Bank, N.A. payment cards ) XXXXXXXXXXXX5101, ) XXXXXXXXXXXX5019, ) XXXXXXXXXXXX1025; Mechanics Bank ) payment card XXXXXXXXXXXX3543; and ) JPMorgan Chase & Co. payment card ) XXXXXXXXXXXX7637 ) ________________________________________ ) 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 18 Leave to Serve “John Doe” Internal Revenue Service summonses. Based upon a review of the 19 Petition, supporting memorandum, and declarations (with exhibits thereto), the Court has determined 20 that the “John Doe” summonses to Wells Fargo Bank, N.A., Mechanics Bank, and JPMorgan Chase & 21 Co. relate to the investigation of particular persons or groups or classes of persons, that there is a 22 reasonable basis for believing that such persons or groups or classes of persons may fail or may have 23 failed to comply with the internal revenue laws of Norway, and that the information sought to be 24 obtained from the examination of the records or testimony (and the identities of the persons with 25 respect to whose liability the summonses are issued) are not readily available from other sources. It 26 is, therefore– 27 28 ORDERED AND ADJUDGED that the Internal Revenue Service, through Revenue Agent ORDER RE “JOHN DOE” IRS SUMMONSES -1- 1 Cheryl Kiger or any other authorized officer or agent, may serve Internal Revenue Service “John 2 Doe” summonses upon Wells Fargo Bank, N.A., Mechanics Bank, and JPMorgan Chase & Co. in 3 substantially the form as attached as Exhibits A, B, and C to the Declaration of Revenue Agent Cheryl 4 Kiger, with the following agreed modifications: 5 1. Paragraph 1 of the Attachment to the “John Doe” Summons to Wells Fargo Bank, 6 N.A. shall be amended so that the documents sought for the client holding payment 7 card account number xxxxxxxxxxxx5101 shall be for the period October 2004 8 through April 2009. 9 2. Paragraph 2 of the Attachment to the “John Doe” Summons to Wells Fargo Bank, 10 N.A. shall be amended so that the documents sought for the client holding payment 11 card account number xxxxxxxxxxxx5109 shall be for the period January 2003 12 through January 2008. 13 3. Paragraph 3 of the Attachment to the “John Doe” Summons to Wells Fargo Bank, 14 N.A. shall be amended so that the documents sought for the client holding payment 15 card account number xxxxxxxxxxxx1025 shall be for the period May 2005 through 16 January 2009. 17 4. Paragraph 1 of the Attachment to the “John Doe” Summons to Mechanics Bank shall 18 be amended so that the documents sought for the client holding payment card account 19 number xxxxxxxxxxxx3543 shall be for the period April 2003 through April 2006. 20 5. Paragraph 1 of the Attachment to “John Doe” Summons to JPMorgan Chase & Co. 21 shall be amended so that the documents sought for the client holding payment card 22 account number xxxxxxxxxxxx7637 shall be for the period January 2003 through 23 January 2006. 24 DONE AND ORDERED this ___ day of ________, 2013. 29 August 25 26 _______________________________ UNITED STATES DISTRICT JUDGE YVONNE GONZALEZ ROGERS 27 28 ORDER RE “JOHN DOE” IRS SUMMONSES -2-

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