[ChuckMcM]

I think you are fighting the good fight Brian!

In tin hat mode, its possible that the subpoena is actually being driven by the justice department not the IRS. As you point out there are a number of less invasive ways of insuring tax compliance but there are not better ways for unwrapping large number of bitcoin transactions involved in ransomware or other extortion or criminal activity. We saw from the MtGox fiasco that when their entire transaction record for all clients was analyzed it identified not only internal corruption but a variety of schemes being used to manipulate or defraud.

Let's assume that Justice has the full transaction records for one or more of the non-US exchanges, by adding all of your records to the mix it would give them the visibility they need to unwind a lot of stuff.

As I understand it, when you make the motion to quash you can compel them to tell you exactly how they were going to use the data. Don't let them be evasive on that point.