IRS Letters 6173, 6174, and CP2000 and Crypto Assets

Ty GainesUpdated at: Aug 31st, 2021

What do IRS Letters 6173, 6174, and 6174-A mean?

The purpose of these letters is to inform taxpayers that the IRS has gathered information about their cryptocurrency holdings and trades. They advise recipients to file amended returns and pay back taxes in light of the IRS' findings.

These letters first started being sent in the summer of 2019, when they were sent to over 10,000 crypto holders. IRS Commissioner Chuck Rettig stated:

Taxpayers should take these letters very seriously. The IRS is expanding efforts involving virtual currency, including increased use of data analytics. This letter is part of a wider campaign to address crypto tax, ranging from taxpayer education to audits and criminal investigations.

You can view examples of the letters on the IRS's press release.

Letter 6173

IRS letter 6173 is the most serious letter. It requires a response by the date on the letter, whether it’s an amended return to properly include crypto or documentation supporting the fact that the crypto tax has been properly filed. 

Letter 6174 and 6174-A

Letters 6174 and 6174-A do not require a specific response, but request action to be taken if cryptocurrency wasn’t properly reported. Letter 6174 states, “We have information that you have or had one or more accounts containing virtual currency but may not know the requirements for reporting transactions involving virtual currency."

Similarly, letter 6174-A states, “We have information that you have or had one or more accounts containing virtual currency but may not have properly reported your transactions involving virtual currency.”

The letters also contain instructions on how to properly file crypto taxes, whether as income (Schedule C), capital gains (Schedule D), or supplemental income, like rental income or royalties (Schedule E). 

CP2000 Notices

The IRS has also begun to send out crypto CP2000 letters / notices to taxpayers who they believe owe taxes on crypto. The IRS sends a CP2000 when the information they have on file doesn’t match what was reported on your tax return. 

The CP2000 requires a response; you can decide whether you agree with the proposed change in tax amount owed, or you can disagree per the instructions on the notice, which involves including supporting documentation.

Because the IRS’s information your crypto likely includes information they’ve received from exchanges, they may have an incomplete picture of what your crypto transaction history is. For example, they may know that you have a large trading volume on Coinbase via the 1099, but without your whole capital gains/losses history via the 8949, they may not know the full story. 

You can respond to the CP2000 with documentation like your complete crypto tax history, calculated via a crypto tax calculator. 

What does the IRS know about my crypto trading history?

Sure, in the early days of Bitcoin, people weren’t thinking about taxation. However, with Bitcoin’s adoption of value and the related IRS guidance, it’s clear that you must report your trades and pay tax on gains and income made with cryptocurrency.

While many believe that crypto is anonymous and cannot be tracked, this is not necessarily the case. Your crypto history can be tracked via your trades on fiat exchanges, and remember that most blockchains are public ledgers. 

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