Coinbase User IRS Block Petition Dismissed After Procedural Failure

A California court on Wednesday dismissed a Coinbase user’s attempt to block an IRS summons for his financial records, in at least the second such case in the past year to fail to reach trial. 

Roger Metz filed a petition in the Northern District of California in May 2025 to quash an IRS summons ordering Coinbase to hand over his financial records in connection with an audit of his 2022 federal tax return. 

His lawyers argued the summons violated his privacy rights, was overbroad and failed to meet basic administrative requirements.

Metz’s lawyers also contended that by the time the IRS issued the summons in 2024, he had already identified the error himself, filed an amended return, and paid the additional tax owed. 

US District Judge Araceli Martínez-Olguín ruled against Metz on Wednesday, finding that he had failed to notify the required government officials of the petition within the 90-day window and dismissed the case on procedural grounds.

Under the Federal Rules of Civil Procedure, defendants must be formally notified of lawsuits to ensure they receive notice and the opportunity to respond. In this case, suing the federal government required notifying three parties within 90 days of filing: the local US Attorney for the district, the US Attorney General in Washington, D.C., and the specific agency being challenged.

Case dismissed over “insufficient service of process”

Metz acknowledged serving the US Attorney’s Office for the Northern District of California and the IRS, but admitted he did not notify the US Attorney General in Washington within the 90-day deadline, according to the court documents. Government lawyers argued it was sufficient grounds for 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 said in her ruling.

“Dismissal of a case is proper when there is insufficient service of process,” she added.

The case was dismissed without prejudice, meaning Metz could file the same petition again at a later date.

Exchanges are required to share user data with tax agencies

Major crypto exchanges are legally required to collect user information and report the taxable income to the IRS, according to Miles Brooks, the director of tax strategy at tax software company CoinLedger.

Related: SEC Chair explains why NFTs fall outside of securities laws

The agency can also issue “John Doe Summons,” which are used to identify large groups of unidentified taxpayers by legally compelling crypto exchanges to turn over records for customers within specific parameters, such as those who transacted $20,000 or more between 2016 and 2020.

In a related case last year, James Harper accused the IRS of violating his Fourth Amendment rights after the agency used a John Doe Summons to collect his data from a crypto exchange. The Supreme Court declined to hear his case.

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