On Wednesday, January 25, 2017, a U.S. District Court in Montana granted a petition from the Internal Revenue Service and issued a “John Doe” summons in order to find the identities of those it suspects of evading taxes. The summons, served to Michael Behr of Bozeman, MT, seeks the records of U.S. taxpayers who had, during the years 2005 to 2016, been issued a “Sovereign Gold Card” from the Panamanian firm Sovereign Management & Legal LTD (SML). These debit cards could have been used in such a manner that would allow U.S. taxpayers to access funds that they had stored overseas in order to avoid paying taxes. The government alleged that SML had offered numerous services — including the facilitation of investments in third-party entities (and even dummy non-profit organizations) — to assist its clients in hiding their assets overseas. The Sovereign Gold Card could then be used by SML clients to access their offshore accounts without revealing their identities or the location of their funds.
The government uses John Doe summonses to ascertain the identities of unknown individuals whom it has reasonable basis to believe are in a class that has committed a crime. In this instance, the IRS obtained the summons to find all those who had owned a Sovereign Gold Card, with the court finding that ownership of such a card constituted a reasonable basis to believe one had committed tax evasion.
The Justice Department press release can be found here: https://www.justice.gov/opa/pr/court-authorizes-service-john-doe-summons-seeking-identities-us-taxpayers-who-have-used-debit
The order granting the John Doe summons can be found here: https://www.justice.gov/opa/press-release/file/931226/download