UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

┐ DAN CARMAN; COIN CENTER; RAYMOND WALSH; │ QUIET INDUSTRIES CORP., │ Plaintiffs-Appellants, │ │ v. > No. 23-5662 │ │ JANET YELLEN, in her official capacity as Secretary of │ the Treasury; UNITED STATES DEPARTMENT OF THE │ TREASURY; CHARLES PAUL RETTIG, in his official │ capacity as Commissioner of the Internal Revenue │ Service; INTERNAL REVENUE SERVICE; MERRICK B. │ GARLAND, Attorney General; UNITED STATES OF │ AMERICA, │ Defendants-Appellees. │ ┘ Appeal from the United States District Court for the Eastern District of Kentucky at Lexington. No. 5:22-cv-00149—Karen K. Caldwell, District Judge.

Argued: May 7, 2024

Decided and Filed: August 9, 2024

Before: MOORE, NALBANDIAN, and BLOOMEKATZ, Circuit Judges.

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COUNSEL ARGUED: Jeffrey S. Hetzel, CONSOVOY MCCARTHY, PLLC, Arlington, Virginia, for Appellants. Geoffrey J. Klimas, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellees. ON BRIEF: Jeffrey S. Hetzel, Cameron T. Norris, CONSOVOY MCCARTHY, PLLC, Arlington, Virginia, for Appellants. Geoffrey J. Klimas, Francesca Ugolini, Ellen Page DelSole, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellees. No. 23-5662 Carman, et al. v. Yellen, et al. Page 2

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OPINION _________________

KAREN NELSON MOORE, Circuit Judge. Plaintiffs Dan Carman, Coin Center, Raymond Walsh, and Quiet Industries Corp. (“plaintiffs”) regularly transact in cryptocurrency for both personal and business matters. They enjoy the privacy and anonymity that cryptocurrency transactions provide. So when Congress passed amendments to 26 U.S.C. § 6050I, a law that now requires reporting of certain cryptocurrency transactions to the federal government, plaintiffs brought this lawsuit against the United States and the agencies in charge of implementing and enforcing § 6050I.1 The district court found that it was without jurisdiction to consider the merits of plaintiffs’ constitutional challenges to the amended § 6050I, because plaintiffs’ claims are either not ripe for adjudication or because the plaintiffs lack standing. Although the district court was correct that one of plaintiffs’ claims is not ripe, several of plaintiffs’ claims are justiciable today. Accordingly, we AFFIRM in part and REVERSE in part the district court’s judgment, and REMAND for proceedings consistent with this opinion.

I. BACKGROUND A. Amended 26 U.S.C. § 6050I

Title 26 U.S.C. § 6050I(a) requires “[a]ny person . . . who is engaged in a trade or business, and . . . who, in the course of such trade or business, receives more than $10,000 in cash” in one or more related transactions to make certain returns to the government. See also R. 27 (Am. Compl. ¶ 29) (Page