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HARPER v. RETTIG

No. 21-1316.

46 F.4th 1 (2022)

James HARPER, Plaintiff, Appellant, v. Charles P. RETTIG, in his official capacity as Commissioner of the Internal Revenue Service; Internal Revenue Service; John Doe IRS Agents 1-10, Defendants, Appellees.

United States Court of Appeals, First Circuit.

August 18, 2022.

Attorney(s) appearing for the Case

Richard Abbott Samp , with whom Aditya Dynar , Caleb Kruckenberg , and New Civil Liberties Alliance were on brief, for appellant.

Kathleen E. Lyon , with whom John J. Farley , Acting United States Attorney, David A. Hubbert , Acting Assistant Attorney General, Francesca Ugolini , and Jennifer M. Rubin were on brief, for appellees.

Before Kayatta, Lipez, and Gelpí, Circuit Judges.

In August 2019, the Internal Revenue Service ("IRS") notified appellant James Harper that it possessed information about his virtual currency accounts and transactions and warned him that he could face civil or criminal enforcement action for inaccurately reporting such transactions. Believing that the IRS had acquired his...

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