James Harper v. Charles P. Rettig, in his official capacity as Commissioner of the Internal Revenue Service, et al.

2021 DNH 056
CourtDistrict Court, D. New Hampshire
DecidedMarch 23, 2021
Docket20-cv-771-JD
StatusPublished
Cited by1 cases

This text of 2021 DNH 056 (James Harper v. Charles P. Rettig, in his official capacity as Commissioner of the Internal Revenue Service, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Harper v. Charles P. Rettig, in his official capacity as Commissioner of the Internal Revenue Service, et al., 2021 DNH 056 (D.N.H. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

James Harper

v. Civil No. 20-cv-771-JD Opinion No. 2021 DNH 056 Charles P. Rettig, in his official capacity as Commissioner of the Internal Revenue Service, et al.

O R D E R

James Harper brought this civil rights suit against

Commissioner Charles Rettig, the IRS, and various unknown

officers of the IRS (John Does 1 through 10) (collectively, "the

government"). Harper alleges that the government violated the

Fourth Amendment, Fifth Amendment, and 26 U.S.C. § 7609(f) by

obtaining records of his financial transactions from third

parties. The government moves to dismiss (doc. no. 12) Harper's

suit for lack of jurisdiction under Federal Rule of Civil

Procedure 12(b)(1) and for failure to state a claim upon which

relief can be granted under Federal Rule of Civil Procedure

12(b)(6). Harper objects.

Standard of Review

When resolving a challenge to the court's subject-matter

jurisdiction under Rule 12(b)(1) or determining whether a claim upon which relief can be granted has been stated under Rule

12(b)(6), the court construes the allegations in the complaint

liberally, treats all well-pleaded facts as true, and resolves

inferences in the plaintiff's favor. Jalbert v. U.S. Securities

& Exchange Comm’n, 945 F.3d 587, 590-91 (1st Cir. 2019); Hamann

v. Carpenter, 937 F.3d 86, 88 (1st Cir. 2019). The court,

however, disregards conclusory allegations that simply parrot

the applicable legal standard. Manning v. Boston Med. Ctr.

Corp., 725 F.3d 34, 43 (1st Cir. 2013).

When addressing subject-matter jurisdiction, in addition to

the complaint, the court may consider other evidence submitted

by the parties without objection. Hajdusek v. United States,

895 F.3d 146, 148 (1st Cir. 2018). The plaintiff, as the party

invoking federal jurisdiction, bears the burden of showing that

subject matter jurisdiction exists when challenged. Lujan v.

Defenders of Wildlife, 504 U.S. 555, 561 (1992).

Background

In 2013, Harper opened an account with "Coinbase," an

entity that "facilitates transactions in virtual currencies such

as bitcoin." Doc. 3 ¶ 18. Coinbase provided terms of agreement

alongside its account, stating, in relevant part, that "Coinbase

takes reasonable precautions, as described herein, to protect

2 your personal information from loss, misuse, unauthorized

access, disclosure, alteration, and destruction." Id. ¶ 25.

In 2013 and 2014, Harper deposited bitcoin into his

Coinbase account. Harper primarily received the bitcoin as

income from consulting work. Harper alleges that he declared

the transactions on his 2013 and 2014 tax returns and states

that he declared all "appropriate income from bitcoin payments,"

including capital gains tax. Id. ¶¶ 30-33. Harper states that

he also paid "appropriate capital gains on any bitcoin income

for tax years 2015 and 2016." Id. ¶ 37. In 2015, Harper

liquidated his holdings in the Coinbase account and by 2016

Harper no longer held any bitcoin in the Coinbase account.

Harper also held bitcoin in accounts with "Abra" and "Uphold".

Harper and his wife liquidated those accounts from 2016 through

the date of the Amended Complaint (August 2020).

In 2016, the IRS sought to enforce an ex parte third-party

"John Doe" administrative summons under 26 U.S.C. §§ 7602,1

1 Section 7602 generally authorizes the IRS to issue administrative summonses "[f]or the purpose of ascertaining the correctness of any return, making a return where none has been made, determining the liability of any person for any internal revenue tax or the liability at law or in equity of any transferee or fiduciary of any person in respect of any internal revenue tax, or collecting any such liability . . . ."

3 7609(f),2 and 7609(h)(2) against Coinbase in the Northern

District of California. Coinbase opposed enforcement of the

summons. Ultimately, the court ordered Coinbase to comply with

a narrowed version of the summons. United States v. Coinbase,

Inc., 2017 WL 5890052, at *1 (N.D. Cal. Nov. 28, 2017) (finding

that the narrowed IRS summons "serves the IRS's legitimate

2 Section 7609(f) details special prerequisites the IRS must satisfy before enforcing an ex parte "John Doe" third-party summons. It says:

Any summons described in subsection (c)(1) which does not identify the person with respect to whose liability the summons is issued may be served only after a court proceeding in which the Secretary establishes that—

(1) the summons relates to the investigation of a particular person or ascertainable group or class of persons,

(2) there is a reasonable basis for believing that such person or group or class of persons may fail or may have failed to comply with any provision of any internal revenue law, and

(3) the information sought to be obtained from the examination of the records or testimony (and the identity of the person or persons with respect to whose liability the summons is issued) is not readily available from other sources.

The Secretary shall not issue any summons described in the preceding sentence unless the information sought to be obtained is narrowly tailored to information that pertains to the failure (or potential failure) of the person or group or class of persons referred to in paragraph (2) to comply with one or more provisions of the internal revenue law which have been identified for purposes of such paragraph.

4 purpose of investigating Coinbase account holders who may not

have paid federal taxes on their virtual currency profits").

In 2019, the IRS sent Harper a letter entitled "Reporting

Virtual Currency Transactions." Doc. 3 ¶ 67; see also doc. 3-6

at 1. As relevant, the IRS's letter told Harper the following:

We have information that you have or had one or more accounts containing virtual currency but may not have properly reported your transactions involving virtual currency, which include cryptocurrency and non-crypto virtual currencies.

Doc. 3 ¶ 68; see also doc. 3-6 at 1. The IRS stated that if

Harper had failed to properly report his "virtual currency

transactions" then he "may be subject to future civil and

criminal enforcement activity." Doc. 3 ¶ 69; see also doc. 3-6

at 1. Additionally, upon Harper's "information and belief,"

John Does 1 through 10 "issued an informal demand" to Abra and

Coinbase for Harper's financial records. Harper believes that

Abra or Coinbase complied with that demand.

Harper's Amended Complaint contains three counts: (I)

violation of the Fourth Amendment; (II) violation of the Fifth

Amendment; and (III) declaratory judgment/violation of 26 U.S.C.

§ 7609(f). As relief for the alleged violations of law stated

in Counts I and II, Harper requests money damages from the

defendants, as well as injunctive and declaratory relief.

Specifically, Harper requests an order declaring § 7602, et

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