Bitcoin Adopters Fail to Prove Forked Coins Didn’t Create Income

Genuine issues of fact around whether two early Bitcoin adopters earned more than $12 million in income between 2017 and 2018 following nine cryptocurrency “hard forks,” precluding summary judgment, the US Tax Court held.

Benjamin Rogovy and Carol Castellon Miranda failed to convince Judge Ronald L. Buch that those transactions weren’t income realization events under IRC Section 61 and that they never had complete dominion over the new, forked coins.

Denying their motion for partial summary judgment March 18, Buch said the pair didn’t meet the three-prong test in the US Supreme Court’s ruling in Commissioner v. Glenshaw Glass Co. ...