It is well settled that upon an order of restitution, based on a criminal tax loss to the government, the IRS can file restitution-based tax liens and collect the restitution in the same manner as if it were a civil tax (liens, levies, et al). However, may the… Read More

An important crypto tax case has emerged in the U.S. District Court in the Middle District of Tennessee, (Jarrett v. U.S.). In the Jarrett case, the taxpayers owned a certain cryptocurrency and engaged in staking activities, and the IRS then taxed their staking rewards as ordinary income. The… Read More

It must be nice to create a false narrative on a whim. This is exactly what the Department of Treasury (IRS) has done with cryptocurrency. In all of this, one thing is clear – the IRS misunderstands cryptocurrency. It is a sad situation really – as crypto could… Read More

The Department of Treasure has issued new guidance that it plans to implement a new requirement for crypto transfers of at least $10,000 be reported to the Internal Revenue Service. This requirement is akin to cash transactions greater than $10,000. Continuing its rhetoric about crypto and criminal activity,… Read More

In a novel crypto tax case out of the U.S. District Court for the Middle District of Tennessee, a taxpayer has challenged the IRS’s ability to treat staking rewards as ordinary income. The taxpayer asserts that staking rewards are the creation of new coins, and that this process… Read More

It is well established that a taxpayer must pay all tax first before filing a refund suit against the IRS in Federal District court. This is called the Flora rule. In Mendu v. United States, the Court of Federal Claims held that penalties for failure to timely file… Read More