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 g…