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126 guides

Crypto enforcement guides

How the IRS finds crypto, what each letter and summons actually means, and what to do before the next notice shows up. Start with the topic that matches the paper on your desk.

IRS Crypto Letters

Letters 6173, 6174 and 6174-A: what each one means and what to do with it.

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 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.

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.

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.

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 the IRS gets exchange records for customers it cannot yet name.

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.

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.

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.

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.

Harper v. Werfel: Why Your Exchange Records Are Not Private From the IRS

The First Circuit held a Coinbase user had no Fourth or Fifth Amendment interest in records the IRS got by John Doe summons. Cert was denied in 2025.

Form 1099-DA Enforcement

Broker reporting under Treas. Reg. 1.6045-1 and the mismatches it creates.

Form 1099-DA Effective Dates: What the Final Regulations Require, Year by Year

Form 1099-DA timeline from Treas. Reg. 1.6045-1: gross proceeds for 2025 sales, basis for 2026 acquisitions, backup withholding relief, DeFi rule repeal.

Your Form 1099-DA Is Wrong: How to Handle a Broker Error Before the IRS Does

A wrong Form 1099-DA can trigger an IRS mismatch notice. How to read the boxes, ask for a correction, and report the right numbers on Form 8949.

Transferred-In Crypto and Zero-Basis 1099-DA Forms: The Mismatch Trap

Crypto moved into an exchange is a noncovered security, so the 1099-DA may show proceeds with no basis. How the IRS matches that and how to protect yourself.

Crypto Backup Withholding: The 24 Percent Rule Brokers Turn On in 2027

IRS relief waived backup withholding on crypto sales in 2025 and 2026. What changes in 2027, who gets withheld at 24 percent, and how to avoid it.

Stablecoin and NFT 1099-DA Reporting: The $10,000 and $600 Thresholds

How brokers may report qualifying stablecoin and specified NFT sales on Form 1099-DA under Treas. Reg. 1.6045-1(d)(10), the thresholds, and the mismatch risk.

Crypto Audits

Exams, document requests, summonses to you, and how far back the IRS can go.

The Crypto Audit IDR: What Form 4564 Asks For and How to Answer It

In a crypto audit, Form 4564 is where the IRS asks for wallet, exchange and basis records. How IDRs work, what to produce, and what happens if you stall.

Letter 3164 in a Crypto Audit: When the IRS Contacts Your Exchange

Before the IRS contacts your exchange, bank or others in a crypto audit, IRC 7602(c) requires advance notice. Letter 3164, the 45-day rule, and your rights.

How Far Back Can the IRS Audit Your Crypto? Three Years, Six Years, or Forever

IRC 6501 gives the IRS three years to assess, six for big omissions or overstated basis, and no limit for no-return or fraud years. How it applies to crypto.

IRS Summons for Your Crypto Records: What IRC 7602 Lets the IRS Demand

An IRS summons served on you for crypto records under IRC 7602: what it can require, how courts enforce it under Powell, and when a lawyer must step in.

Appealing a Crypto Audit: The Protest, the $25,000 Line, and IRS Appeals

Disagree with a crypto audit? How to request IRS Appeals, when a formal written protest is required, the statute time Appeals needs, and what to put in it.

Crypto Notice of Deficiency: Your 90 Days to Get Into Tax Court

A notice of deficiency after a crypto audit or CP2000 gives you a fixed window to petition the U.S. Tax Court without paying first. What to do, day by day.

Burden of Proof in a Crypto Audit: Who Has to Prove What

In a crypto tax dispute, the taxpayer generally bears the burden, but IRC 7491 and 7454 shift it on credible evidence, penalties and fraud. How it works.

Crypto Penalties

Accuracy, fraud and filing penalties on unreported crypto, and the defenses.

Answered “No” to the Digital Asset Question When It Was “Yes”? Read This

The Form 1040 digital asset question is signed under penalties of perjury, and the IRS fraud handbook treats an intentional wrong “No” as a fraud indicator.

The 20 Percent Crypto Penalty: How IRC 6662 Applies to Unreported Crypto

How the IRC 6662 accuracy-related penalty hits unreported crypto: negligence, the 10 percent or $5,000 test, the reasonable cause defense, and approval rules.

The 75 Percent Crypto Fraud Penalty: How IRC 6663 Works and What the IRS Must Prove

The IRC 6663 civil fraud penalty adds 75 percent in crypto cases where the IRS proves fraud by clear and convincing evidence. How it works and how to defend.

Supervisory Approval of Crypto Penalties: The IRC 6751(b) Defense

Most crypto penalties need written supervisory approval under IRC 6751(b) and Treas. Reg. 301.6751(b)-1. When it is required, the deadlines, and how to check.

Reasonable Cause for Crypto Penalties: What Works, What Doesn’t

How reasonable cause and good faith defeat crypto penalties under IRC 6664(c) and Treas. Reg. 1.6664-4, including reliance on preparers, software and 1099s.

The IRS Crypto Fraud Indicators: What IRM 25.1.2.11 Tells Examiners to Look For

IRM 25.1.2.11 lists the indicators of fraud IRS examiners look for in crypto cases, from false digital asset answers to mixers. What each means for you.

Never Filed Because of Crypto? The Fraudulent Failure to File Penalty Under IRC 6651(f)

IRC 6651(f) raises the failure to file penalty from 5 to 15 percent a month, capped at 75 percent, when not filing was fraudulent. How it applies to crypto.

How Crypto Penalties Stack: 6651, 6662, 6663 and What Cannot Apply Together

Which IRS penalties can apply together on unreported crypto, and which cannot: failure to file and pay, the 20% accuracy penalty, and 75% fraud penalties.

More guides

Earlier guides on crypto tax debt, notices, settlements and reporting.

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