IRS seeks Gmail and Yahoo records tied to alias accounts in offshore tax probe
Raju Mukhi v. Commissioner. Docket. 15315-19 & 4329-22L.
The IRS has asked the Tax Court to schedule a remote hearing to issue document subpoenas in the consolidated Raju Mukhi cases (Docket. 15315-19 & 4329-22L), which involve income tax, civil fraud, and foreign reporting penalties for 2002 through 2013.
The government wants Yahoo, Google, and possibly other third parties to turn over emails tied to an alias account that taxpayer Raju J. Mukhi allegedly used to communicate with Liechtenstein advisors and foreign bankers.
The motion frames this as a discovery problem: years of incomplete responses from the taxpayer, new documents from Liechtenstein, and now a push to build the record through third-party subpoenas, over privilege objections.
The Law in Play
The motion sits in the Tax Court’s ordinary deficiency and collection review jurisdiction. The IRS is pursuing income tax deficiencies, the civil fraud penalty, and “various reporting penalties” tied to foreign entities and accounts.
In procedure, the IRS relies on Tax Court Rule 147, which governs subpoenas and includes mechanisms to modify or quash them and to address privileged material. The government argues that any privilege questions can be handled under Rule 147(d)(3) and (e)(2) after subpoenas are issued, not used to block them in advance.
The core legal questions right now are procedural and evidentiary:
Can the IRS use Tax Court subpoenas to obtain a complete set of emails from third-party providers and related individuals?
How should the court manage potential attorney-client communications in those third-party productions?
Petitioner’s side is pressing the privilege angle and process: they object to the motion, insist on a protocol to prevent disclosure of privileged communications, and dispute the IRS’s characterization of the discovery history while reserving the right to seek court-ordered safeguards.
Timeline
Early 2000s: Mukhi meets with Interadvice representatives in Vaduz, Liechtenstein, about forming entities to “organize” his financial affairs, including Sukhmani Partners II and related structures.
2002–2013: Tax years at issue, involving alleged unreported income from foreign entities and accounts, fraud, and foreign reporting penalties.
February 9, 2023: The IRS issues an informal Branerton discovery request, including a request for all communications between Mukhi and Interadvice.
April 10, 2023: Petitioner’s counsel replies that Mukhi is determining whether he has responsive documents and will supplement if he identifies any. No supplementation follows.
February 22, 2023: Yahoo sent a notice that the alias account had gone inactive and may have had emails deleted, and was later reactivated when “Jack” signed back in (later attached as Exhibit A).
September 26, 2025: IRS Exchange of Information Office forwards the “Liechtenstein Production” to trial counsel. The production includes 2009–2013 emails between Mukhi and Interadvice showing he used the alias “Jack Thatcher” and the email address jack1234567_2001@yahoo.com.
October 29, 2025: IRS serves what the petitioner calls a second set of interrogatories, asking, among other things, about email accounts and discovery efforts.
November 26, 2025: Mukhi answers interrogatories. He lists numerous email accounts, admits using the two “Jack1234567_2001” Yahoo and Gmail accounts to communicate with foreign bankers and advisors, and explains that he tried and failed to access the Yahoo alias account for prior discovery.
December 2, 2025: IRS counsel shares a draft of this motion with petitioner’s counsel, who provides a detailed block-quoted objection statement for inclusion.
December 3, 2025: IRS files the Motion for Document Subpoena Hearing, asking the court to schedule a remote hearing in about ten weeks and to bless subpoenas to Yahoo, Google, the sister (Asha Advani), and other possible custodians.
Present: No trial date has been set. The motion is pending before Judge Greaves.
The Larger Story
This motion is a textbook example of how cross-border planning, opaque intermediaries, and slow-rolling discovery turn a tax case into a multi-front evidentiary fight.
The IRS is using treaty information channels and third-party subpoenas to backfill what it says the taxpayer should have produced years ago. In contrast, the taxpayer relies on privilege, scope objections, and the ambiguity of earlier discovery requests to limit what ends up in the record.
What It Means in Practice
Expect more third-party subpoenas in offshore cases where taxpayers used intermediaries, aliases, or foreign advisors and provided incomplete responses to IRS discovery requests.
Email providers are not background noise here; counsel need to inventory and manage all personal, business, and alias accounts early, including old or “inactive” addresses.
Privilege cannot be handled casually. Build and document a real protocol for privilege review, logs, and coordination with third-party custodians before anything is produced.
Discovery letters and Branerton requests need tight drafting. Vague “all documents” language becomes a battlefield years later when one side claims a narrow meeting-only scope, and the other claims everything.
In fraud and foreign reporting penalty cases, alias accounts and inconsistencies between taxpayer responses and treaty-partner productions are likely to feature prominently in the government’s scienter narrative.
Next Steps
The immediate next step is Judge Greaves's scheduling decision on whether and when to hold the requested remote subpoena hearing, and, if granted, how to structure the timing and protocol for third-party productions and privilege review under Rule 147.
In offshore audits, the objective evidence fight often shifts from what the taxpayer turns over to what foreign authorities and email providers can be compelled to produce later.