The Justice Department says there is no allegation in the suit that Coinbase has engaged in any wrongdoing, but that the IRS is using the John Doe summonses to get records about possible violations of internal revenue laws by individuals whose identities are not known. (ibtimes.com)
The court of appeals handles all appeals except those in the supreme court's exclusive jurisdiction: challenges to the validity of a United States statute or treaty, the validity of a state constitutional provision or statute, cases requiring construction of revenue laws, the title to state office and cases where the death penalty is imposed. (ballotpedia.org)
«Rather, the IRS uses John Doe summonses to obtain information about possible violations of internal revenue laws by individuals whose identities are unknown.» (gizmodo.com)