Crypto tax enforcement defense
The IRS is reading the blockchain paper trail.
Exchanges file Form 1099-DA. Courts have authorized John Doe summonses for exchange records. Letters 6173, 6174 and 6174-A went out to crypto holders. If one of those roads now leads to you, this site explains exactly where you stand and what to do next.
how the IRS finds crypto
- 01Broker reportingForm 1099-DA gross proceeds for digital asset sales on or after January 1, 2025, under Treas. Reg. 1.6045-1.
- 02Third-party recordsCourt-approved John Doe summonses under IRC 7609(f) for exchange customers the IRS cannot yet name.
- 03LettersLetters 6173, 6174 and 6174-A tell you the IRS has information about your virtual currency accounts.
- 04ExaminationInformation Document Requests, third-party contacts and IRC 7602 summonses for your wallet records.
- 05Penalties20 percent accuracy penalties under IRC 6662, 75 percent civil fraud penalties under IRC 6663.
Start here
Which letter is in your hand?
The three IRS virtual currency letters look alike and are not alike. One asks for a signed answer by a deadline. Two do not. Read the one that matches yours.
6173
Letter 6173
The one with a respond-by date. Ignore it and the letter itself says the IRS may refer your account for examination.
6174
Letter 6174
The education letter. No response required, but it still means the IRS has your account information.
6174-A
Letter 6174-A
Education-plus. No response required, and a warning that other enforcement correspondence may follow.
Not sure which one you got? Compare all three side by side.
Five enforcement tracks
5 guides
IRS Crypto Letters
Letters 6173, 6174 and 6174-A: what each one means and what to do with it.
5 guides
John Doe Summonses
How the IRS gets exchange records for customers it cannot yet name.
5 guides
Form 1099-DA Enforcement
Broker reporting under Treas. Reg. 1.6045-1 and the mismatches it creates.
7 guides
Crypto Audits
Exams, document requests, summonses to you, and how far back the IRS can go.
8 guides
Crypto Penalties
Accuracy, fraud and filing penalties on unreported crypto, and the defenses.
New enforcement guides
All 126 guidesIRS Crypto Letters
IRS Letter 6174 for Crypto: No Response Required, Plenty of Consequences
IRS Letter 6174 says you do not need to respond. Here is what it means that the IRS has your crypto account information, and what to do anyway.
IRS Crypto Letters
IRS Letter 6174-A: The Crypto Letter That Warns of Enforcement
Letter 6174-A says you may not have properly reported crypto and that more IRS letters may follow. What it means and how to respond on your terms.
IRS Crypto Letters
Letters 6173, 6174 and 6174-A Compared: Which Crypto Letter Did You Get?
Side-by-side comparison of IRS crypto Letters 6173, 6174 and 6174-A: deadlines, required responses, what each signals, and the next move for each.
IRS Crypto Letters
Answering Letter 6173 When You Already Reported Your Crypto
Got IRS Letter 6173 but reported your crypto correctly? How to write the statement of facts, what to attach, and the risk of signing under penalties of perjury.
IRS Crypto Letters
Ignored an IRS Crypto Letter? What Happens Next
Ignored Letter 6173, 6174 or 6174-A? What the IRS can do next, from examination to penalties, and how to get back on offense before the next notice.
John Doe Summonses
How an IRS John Doe Summons Works: IRC 7609(f) in Plain English
How the IRS gets exchange records for crypto customers it cannot name: the IRC 7609(f) test, the ex parte court step, no notice to you, and what it means.
John Doe Summonses
The Coinbase John Doe Summons: What the Court Let the IRS Have
The 2016 IRS John Doe summons to Coinbase, narrowed to 14,355 accounts: which records the court enforced in 2017, which it refused, and why it still matters.
John Doe Summonses
The Kraken John Doe Summons and the “Narrowly Tailored” Fight
In 2021 a federal judge pushed back on the IRS John Doe summons to Kraken as too broad. What the order said, how the IRS narrowed it, and who was covered.
John Doe Summonses
Circle, SFOX and a Bank: How the IRS Widened Its Crypto Summons Net
After Coinbase, the IRS got court approval for John Doe summonses to Circle, SFOX and M.Y. Safra Bank. Who was covered, which years, and the bank angle.
Who writes this
A tax lawyer, not a software company.
I'm Darrin T. Mish. I have been licensed to practice law since 1993, and my firm handles federal tax controversies out of Tampa. Crypto cases run through the same IRS machinery as every other case: letters, examinations, summonses, penalties, appeals and Tax Court. The asset is new. The playbook is not.
Every guide on this site cites the Code section, regulation, IRS manual provision or court record it relies on, so you can check it yourself.
About the attorneyVerify any of this with the bars and courts directly. How to check
Let's talk
Got a crypto letter, a summons notice, or an audit?
Bring the letter and whatever records you have. We will sort out what is real, what is urgent, and what the next move is.
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