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Ryan Sciortino

Ryan is an associate in Baker McKenzie’s Tax and Global Wealth Management practice groups. Prior to joining Baker McKenzie, Ryan worked in the national tax departments of two of the world’s largest accounting firms.

In United States v. Payward Ventures, Inc., the Internal Revenue Service (IRS) sought enforcement of a John Doe summons served upon Payward Ventures and its subsidiaries (referred to collectively as “Kraken”), which the court had previously preliminarily approved. Following Kraken’s refusal to comply with the summons, the IRS sought to enforce the summons. The dispute between Kraken and the IRS focused on whether the information sought by the IRS was relevant and imposed an undue burden of compliance upon Kraken.