From the summons[1]:

"The Narrowed Summons “do[es] not include users: (a) who only bought and held bitcoin during the 2013-15 period; or (b) for which Coinbase filed Forms 1099-K during the 2013-15 period.” (Id. ¶ 2.) According to Coinbase, the Narrowed Summons requests information regarding 8.9 million transactions and 14,355 account holders."

Looks like the IRS is encouraging hodling /s

Seriously though I'm glad that the tax court reduced the reporting requirement to just people who likely have a tax obligation (bought and sold) than people who merely bought and hadn't sold.

[1]https://assistly-production.s3.amazonaws.com/75687/kb_articl...