United States v. John Does, Southern District of New York (Dec. 23, 2024)
raw: John Doe Summonses Order
John Doe Summonses Order (S.D.N.Y. Dec. 23, 2024)
summary
The U.S. District Court granted an ex parte petition to serve 'John Doe' summonses to financial institutions and companies, investigating potential tax fraud by individuals who used Trident Trust Group's services between 2014 and 2023.
paragraph
The Court granted an ex parte petition to serve 'John Doe' summonses to various financial institutions and companies, including FedEx, DHL, UPS, and major banks. The summonses are related to an investigation of potential tax fraud or misconduct by individuals who used the services of Trident Trust Group to establish or maintain foreign financial accounts or assets between 2014 and 2023. The investigation is focused on determining whether these individuals have complied with their U.S. income tax reporting and disclosure obligations.
narrative
The United States District Court for the Southern District of New York has granted an ex parte petition for leave to serve 'John Doe' summonses to various financial institutions and companies, including FedEx, DHL, UPS, and major banks. The summonses are related to an investigation of an ascertainable group or class of persons who may have failed to comply with their tax obligations, specifically reporting their worldwide income and disclosing their ownership of certain foreign assets. The investigation is focused on individuals who used the services of Trident Trust Group to establish, maintain, or control foreign financial accounts or assets between 2014 and 2023. The Court has determined that there is a reasonable basis for believing that this group has failed to comply with their tax obligations, and the summonses are narrowly tailored to obtain information relevant to the investigation. The outcome of the investigation is not specified in the document.
Classified non-corporate(confidence 95%). No EDGAR filing fingerprint (criminal/DOJ-side scheme). detection rule →
Parties
United States of AmericaJohn Does
Keywords
summonses orderjohndoesummonsesorder
Extracted insights
Entities 18
- person John Does ×2
- organization Bank Of America, National Association
- organization Citibank, National Association
- organization Deutsche Bank Trust Company Americas
- organization DHL Express (USA), Inc.
- organization Federal Reserve Bank Of New York
- organization FedEx Corporation
- organization Hsbc Bank USA, National Association
- agency Internal Revenue Service
- person John P. Cronan
- organization Nevis Services Limited
- person Randy Hooczko
- organization The Bank Of New York Mellon Corporation
- organization The Clearing House Payments Company LLC
- organization Trident Trust Group
- organization UBS AG
- organization United Parcel Service, Inc.
- organization Wells Fargo Bank, National Association
Triples 3
- John Does used services of Trident Trust Group, including its predecessors, subsidiaries, divisions, affiliates, and associates, to establish, maintain, operate, or control foreign financial accounts and assets
- Court determined John Doe summonses relate to investigation of a group or class of persons who may have failed to file U.S. income tax returns and disclose foreign assets
- Internal Revenue Service may serve John Doe summonses upon the Summonsed Parties
Text layers
Extracted body text (3,740c)
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK IN THE MATTER OF THE TAX LIABILITIES OF: JOHN DOES, United States taxpayers who, at any time during the years ended December 31, 2014, through December 31, 2023, used the services of the Trident Trust Group, including its predecessors, subsidiaries, divisions, affiliates, and associates, to establish, maintain, operate, or control any foreign financial account or other foreign asset; any foreign corporation, company, trust, foundation or other legal entity; or any foreign or domestic financial account or other asset in the name of such foreign entity. No. 24 Misc. 594 ORDER GRANTING EX PARTE PETITION FOR LEAVE TO SERVE “JOHN DOE” SUMMONSES THIS MATTER is before the Court upon the United States of America's “Ex Parte Petition for Leave to Serve “John Doe” Summonses” (the “Petition”). Based upon a review of the Petition and supporting documents, the Court has determined that the “John Doe” summonses to FedEx Corporation; DHL Express (USA), Inc.; United Parcel Service, Inc.; the Federal Reserve Bank of New York; The Clearing House Payments Company LLC; HSBC Bank USA, National Association; The Bank of New York Mellon Corporation; Wells Fargo Bank, National Association; Citibank, National Association; UBS AG; Bank of America, National Association; Deutsche Bank Trust Company Americas; and Nevis Services Limited (the “Summonsed Parties”) relate to the investigation of an ascertainable group or class of persons, that there is a reasonable basis for believing that such group or class of persons has failed or may have failed to comply with their obligations to file U.S. income tax returns reporting their worldwide income from all sources and to disclose their ownership of certain foreign assets to the U.S. government pursuant to 26 U.S.C. §§ 61, 6011, 6012, 6038, 6038D, 6039F, 6046 & 6048, and 31 U.S.C. §§ 5314 & 5321, http://www.google.com/search?q=26++u.s.c.++61 http://www.google.com/search?q=26++u.s.c.++61 http://www.google.com/search?q=26++u.s.c.+6011 http://www.google.com/search?q=26++u.s.c.+6012 http://www.google.com/search?q=26++u.s.c.+6038 http://www.google.com/search?q=26++u.s.c.+6038d http://www.google.com/search?q=26++u.s.c.+6039f http://www.google.com/search?q=26++u.s.c.+6046 http://www.google.com/search?q=26++u.s.c.+6048 http://www.google.com/search?q=26++u.s.c.+31 http://www.google.com/search?q=31+u.s.c.++5314 http://www.google.com/search?q=31+u.s.c.+5321 http://scholar.google.com/scholar?q=24+misc.+594&btnG=&hl=en&as_sdt=6 2 that the information sought to be obtained from the examination of the records or testimony (and the identities of the persons with respect to whose liability the summonses are issued) is not readily available from other sources, and that the summonses are narrowly tailored to information that pertains to the failure (or potential failure) of the group or class to comply with their obligations to file U.S. income tax returns reporting their worldwide income from all sources and to disclose their ownership of certain foreign assets to the U.S. government. It is therefore: ORDERED AND ADJUDGED that the Internal Revenue Service, through Senior Revenue Agent Randy Hooczko or any other authorized officer or agent, may serve Internal Revenue Service “John Doe” summonses upon the Summonsed Parties in substantially the form as attached as Exhibits A through M to the Declaration of Randy Hooczko dated December 16, 2024. A copy of this Order shall be served together with each summons. SO ORDERED. Dated: ______________ New York, New York ___________________________________ HON. ________________________ United States District Judge December 23, 2024 JOHN P. CRONAN
OCR text (3,945c · textlayer · 95% conf)
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK IN THE MATTER OF THE TAX LIABILITIES OF: JOHN DOES, United States taxpayers who, at any time during the years ended December 31, 2014, through December 31, 2023, used the services of the Trident Trust Group, including its predecessors, subsidiaries, divisions, affiliates, and associates, to establish, maintain, operate, or control any foreign financial account or other foreign asset; any foreign corporation, company, trust, foundation or other legal entity; or any foreign or domestic financial account or other asset in the name of such foreign entity. No. 24 Misc. 594 ORDER GRANTING EX PARTE PETITION FOR LEAVE TO SERVE “JOHN DOE” SUMMONSES THIS MATTER is before the Court upon the United States of America's “Ex Parte Petition for Leave to Serve “John Doe” Summonses” (the “Petition”). Based upon a review of the Petition and supporting documents, the Court has determined that the “John Doe” summonses to FedEx Corporation; DHL Express (USA), Inc.; United Parcel Service, Inc.; the Federal Reserve Bank of New York; The Clearing House Payments Company LLC; HSBC Bank USA, National Association; The Bank of New York Mellon Corporation; Wells Fargo Bank, National Association; Citibank, National Association; UBS AG; Bank of America, National Association; Deutsche Bank Trust Company Americas; and Nevis Services Limited (the “Summonsed Parties”) relate to the investigation of an ascertainable group or class of persons, that there is a reasonable basis for believing that such group or class of persons has failed or may have failed to comply with their obligations to file U.S. income tax returns reporting their worldwide income from all sources and to disclose their ownership of certain foreign assets to the U.S. government pursuant to 26 U.S.C. §§ 61, 6011, 6012, 6038, 6038D, 6039F, 6046 & 6048, and 31 U.S.C. §§ 5314 & 5321, Case 1:24-mc-00594-JPC Document 7 Filed 12/23/24 Page 1 of 2 http://www.google.com/search?q=26++u.s.c.++61 http://www.google.com/search?q=26++u.s.c.++61 http://www.google.com/search?q=26++u.s.c.+6011 http://www.google.com/search?q=26++u.s.c.+6012 http://www.google.com/search?q=26++u.s.c.+6038 http://www.google.com/search?q=26++u.s.c.+6038d http://www.google.com/search?q=26++u.s.c.+6039f http://www.google.com/search?q=26++u.s.c.+6046 http://www.google.com/search?q=26++u.s.c.+6048 http://www.google.com/search?q=26++u.s.c.+31 http://www.google.com/search?q=31+u.s.c.++5314 http://www.google.com/search?q=31+u.s.c.+5321 http://scholar.google.com/scholar?q=24+misc.+594&btnG=&hl=en&as_sdt=6 2 that the information sought to be obtained from the examination of the records or testimony (and the identities of the persons with respect to whose liability the summonses are issued) is not readily available from other sources, and that the summonses are narrowly tailored to information that pertains to the failure (or potential failure) of the group or class to comply with their obligations to file U.S. income tax returns reporting their worldwide income from all sources and to disclose their ownership of certain foreign assets to the U.S. government. It is therefore: ORDERED AND ADJUDGED that the Internal Revenue Service, through Senior Revenue Agent Randy Hooczko or any other authorized officer or agent, may serve Internal Revenue Service “John Doe” summonses upon the Summonsed Parties in substantially the form as attached as Exhibits A through M to the Declaration of Randy Hooczko dated December 16, 2024. A copy of this Order shall be served together with each summons. SO ORDERED. Dated: ______________ New York, New York ___________________________________ HON. ________________________ United States District Judge December 23, 2024 JOHN P. CRONAN Case 1:24-mc-00594-JPC Document 7 Filed 12/23/24 Page 2 of 2