A new IRS Chief Counsel Advice 202114020 Memorandum was issued answering the question of whether a taxpayer who received Bitcoin Cash as a result of the August 1, 2017, Bitcoin hard fork has gross income under section 61 of the Internal Revenue Code. The answer is yes. A taxpayer who received Bitcoin Cash as a result of the August 1, 2017, Bitcoin hard fork has gross income because the taxpayer had an “accession to wealth” under section 61 of the Code. See Revenue Ruling 2019-24. The date of receipt and fair market value to be included in gross income will be dependent on “when” the taxpayer obtained dominion and control over the Bitcoin Cash.