A federal judge in the Northern District of California on Wednesday dismissed a Coinbase user’s petition seeking to block an IRS summons for his account records, ruling the challenge failed on procedural grounds.
Roger Metz had filed the petition in May 2025 asking the court to quash an IRS summons demanding Coinbase produce his financial records in connection with an audit of his 2022 federal tax return. His attorneys argued the summons infringed on privacy, was overbroad and did not satisfy administrative requirements. They also said Metz had already discovered the error, filed an amended return and paid the additional tax by the time the IRS issued the summons in 2024.
U.S. District Judge Araceli Martínez-Olguín dismissed the case after finding Metz did not timely notify required government officials within the 90-day window mandated when suing the federal government. Under the Federal Rules of Civil Procedure, plaintiffs must serve notice so defendants receive an opportunity to respond; when the United States is a defendant, that service requires notifying the U.S. Attorney for the district, the U.S. Attorney General in Washington, D.C., and the specific agency involved.
Metz acknowledged serving the U.S. Attorney’s Office for the Northern District of California and the IRS, but admitted he did not serve the U.S. Attorney General in Washington within 90 days. Government lawyers argued that failure justified dismissal. “In his opposition brief, Metz does not offer any explanation for his failure to serve the United States within 90 days after filing his petition, much less that he had good cause,” Judge Martínez-Olguín wrote, adding that dismissal is appropriate when there is insufficient service of process. The case was dismissed without prejudice, allowing Metz to refile if he corrects the service defect.
The ruling comes amid broader enforcement activity requiring crypto exchanges to collect customer information and report taxable income to the IRS. Tax experts note the agency can also issue ‘‘John Doe’’ summonses to identify groups of taxpayers by compelling exchanges to turn over records for customers who meet specified criteria (for example, transactions above a dollar threshold during a given period).
Miles Brooks, director of tax strategy at CoinLedger, said exchanges are legally obliged to maintain and report certain user information to tax authorities. A related challenge last year by James Harper, who alleged a John Doe summons violated his Fourth Amendment rights, failed to progress after the Supreme Court declined to review the case.
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