Kostelanetz partner Caroline Ciraolo and associate Abigail Burke will present “Are You a John Doe? The John Doe Summons as a Force Multiplier.” to the Georgetown University Law Center’s Graduate Tax Scholars on February 12, 2025, in Washington, DC. Caroline is an adjunct professor in Georgetown’s Graduate Tax Program, teaching Criminal Tax Law & Procedure and International Tax Controversies. Abigail is an associate in Kostelanetz’s Washington, D.C. office and is a vice-chair of the Women in Tax Law Forum of the Tax Section of the American Bar Association.

The John Doe summons has become a powerful tool for the IRS to find tax evaders and owners of undisclosed offshore accounts when the agency does not know their identities. Combined with global information-sharing agreements like FATCA, the John Doe summons is one of the most formidable tools that the IRS has at its disposal. As federal courts grant the IRS wider usage of John Doe summons to go beyond international tax controversy cases, even including going after gig workers domestically, tax controversy professionals must create procedures for both their clients and their own firms to prepare for John Doe summonses.

You can learn more about the graduate tax program here.

Caroline, a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, focuses her practice on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions, serving as an expert witness in tax controversy-related matters, and mediating civil tax disputes at the administrative stage and in litigation.