When the IRS shows up, you need someone who reads the blockchain.
IRS crypto examinations fail for a consistent reason: the revenue agent understands the tax law but not the technology. We bridge that gap. Saim brings chain-level evidence, broker reconciliation, and written methodology memos to every engagement — and has closed CP2000 notices with $0 additional tax on proposed assessments that exceeded $90,000.
Schedule a 30-minute intake →Every type of IRS crypto challenge, covered.
Automated Underreporter Proposals
The most common IRS crypto letter. The Service received 1099-K or 1099-DA data showing proceeds and assumes $0 cost basis. A well-documented response — filed within the 60-day window — can reduce the proposed assessment to zero. We draft the response, prepare the Form 8949 correction, and gather the on-chain evidence.
Pre-Examination Contact
A CP2501 is the IRS asking you to reconcile a discrepancy before opening a formal examination. Responding correctly — with documentation — can close the matter at this stage. We treat every CP2501 as seriously as a full exam, because it can become one.
Correspondence & Field Audit
If your return is selected for full examination — whether correspondence or field — we represent you through every information document request (IDR), every response deadline, and every appeals conference. Saim handles the case from first contact to resolution.
Hobby vs. Business Disputes
The IRS frequently challenges whether mining, staking, and DeFi activity constitutes a trade or business under IRC §162. We defend the business classification with profit-motive evidence, operational documentation, and published IRS and Tax Court authority.
Memo-backed positions. Chain-level evidence. Broker reconciliation.
- Memo-backed positions. Every non-obvious tax position we defend has a written methodology memo explaining the authority (statute, regulation, notice, revenue ruling) and applying it to the specific facts. These memos are prepared before the letter arrives — not after.
- Chain-level evidence. We pull raw blockchain data to substantiate the facts the IRS is disputing: acquisition dates, amounts, transaction hashes, wallet addresses. Exchange CSVs are supporting evidence; the chain is the primary record.
- Broker reconciliation. When the IRS is using 1099-K or 1099-DA data to assert a discrepancy, we rebuild the reconciliation showing what the broker reported vs. what actually happened — and why they differ. This is frequently dispositive.
- Direct representation. Saim appears on the Power of Attorney (Form 2848). We communicate directly with the revenue agent. You do not need to be on the calls, answer IDRs yourself, or explain blockchain technology to someone who doesn’t understand it.
What audit defense looks like in practice.
$0 additional tax on a $94K CP2000 proposed assessment
Client received a CP2000 proposing $94,000 in additional tax based on 1099-K gross proceeds with $0 assumed basis. We reconstructed the client’s cost basis from on-chain data, filed a corrected Form 8949 with Code B adjustments, and submitted a response memo documenting the reconciliation. The IRS accepted the response and closed the matter with $0 additional tax owed.
Position upheld on $61K staking income deferral
Client had deferred reporting staking rewards until disposition, citing the Jarrett decision (W.D. Tenn. 2022). The IRS challenged the position citing Rev. Rul. 2023-14. We filed a defense memo documenting the Jarrett refund acceptance by the U.S. government in 2022, the arguable conflict in IRS guidance, and the good-faith basis for the position. The position was upheld without penalty.
Mining deductions preserved after hobby-loss challenge
Client’s mining Schedule C was challenged as a hobby under IRC §183. We documented 18 months of operational records, equipment depreciation schedules, power cost tracking, and profit motive evidence. The IRS closed the examination accepting all deductions as ordinary business expenses.
Received an IRS letter about crypto?
Don’t respond on your own. The 60-day CP2000 window moves fast, and a poorly drafted response can make things worse. Schedule a 30-minute intake and we’ll review the letter at no cost.
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