What tax authority do you refer to here, specifically? IRS, CRA, or a tax agency of some other country? To tax Satoshi, you would first have to find out what jurisdiction he belongs to, which citizenship he has, who he is and if he is still alive, and whether he is a human being at all. I don't think this is the thing that the tax authorities would want to invest their time and effort in. Anyway, until he sells his coins for fiat, you basically can't tax him in most jurisdictions