Crypto Tax Legislation Tracker
Federal Tax Controversy & Litigation

Law Offices of
Miles Fuller

Former Senior Counsel, IRS Office of Chief Counsel. Lead Attorney, IRS Digital Asset Cadre. Litigation experience with conservation easements, microcaptive insurance arrangements, retirement account and structured financial arrangements. Collection expertise with bankruptcy tax issues, collection due process, liens and levies. Now representing taxpayers in federal tax disputes — from audit through litigation.

View Practice Areas
15+
Years IRS Counsel
40+
Speaking Engagements
25+
Court Opinions
10
Years Digital Assets
Practice Areas

Federal Tax Controversy
from audit to appeal

Full-spectrum representation at every stage of a federal tax dispute — from the first IRS examination notice through collection proceedings, administrative appeals, and litigation before the United States Tax Court. With more than 15 years inside the IRS, Miles Fuller brings an unmatched perspective on how the government builds and pursues its cases.

01

IRS Audit Defense

Representation through all phases of IRS examination — correspondence, office, and field audits. Strategic preparation of documentation, issue identification, and direct advocacy with revenue agents and their managers. Former IRS counsel perspective on how examiners develop and present cases.

02

IRS Appeals

Preparation and presentation of written protests to the IRS Independent Office of Appeals. Experienced in negotiating favorable settlements of examination adjustments and collection matters at the administrative level — without the cost and uncertainty of litigation.

03

Tax Court Litigation

Full representation in the United States Tax Court, including deficiency cases, collection due process hearings, innocent spouse cases, and penalty disputes. Former IRS trial attorney with significant courtroom experience and successes — over 20 cases tried and 6 precedent-setting opinions.

04

IRS Collection

Strategic resolution of IRS collection matters including installment agreements, offers in compromise, currently not collectible status, levy and lien releases, and collection due process hearings. Extensive background handling complex collection matters with a deep understanding of how the IRS determines reasonable collection potential and ability to pay.

05

Penalty Abatement

Preparation of first-time abatement requests and reasonable cause submissions under §6651, §6662, and related provisions. Written protests and appeals of penalty assessments. Former IRS counsel experience with how the Service evaluates and responds to abatement requests.

06

Digital Asset Tax Issues

Ten years working on digital asset tax issues both within and outside of the IRS. Former Lead Attorney of the IRS Digital Asset Cadre with the deepest possible knowledge for taxpayers facing IRS scrutiny of their cryptocurrency or digital asset activity. Policy advocate and thought leader with the real-world litigation experience necessary to support taxpayers through digital asset matters.

The Advantage

Inside
Knowledge.
Your Corner.

Fifteen years inside the IRS Office of Chief Counsel means understanding exactly how the government builds its cases — and where the opportunities lie.

⚖

IRS Perspective, Taxpayer Advocacy

Having spent 15 years trying cases in Tax Court, representing the IRS in bankruptcy courts, and advising IRS examination and collection divisions, Miles Fuller knows precisely how IRS and Department of Justice attorneys, and revenue agents and officers approach cases — what they look for, what persuades them, and where cases can be won or settled.

📋

Meticulous Case Preparation

Tax disputes are won and lost on documentation and legal analysis. Every response, protest, and Tax Court filing is built with the same rigor brought to government litigation — comprehensive, well-organized, and calibrated to the specific decision-maker at each stage.

◎

Direct Partner Access

As a solo practitioner, every client works directly with Miles Fuller throughout the engagement. The attorney who analyzed your case is the attorney who drafts your protest, appears at Appeals, and argues your case before the Tax Court — no hand-offs, no associates.

◈

Deep Digital Asset Expertise

As the architect of the IRS's own digital asset examination methodology, Miles Fuller doesn't just understand crypto tax law — he helped write the playbook the IRS uses. That expertise is now deployed exclusively in service of taxpayers facing digital asset scrutiny.

Specialty Focus

Digital Asset
Tax Controversy

Former Lead Attorney — IRS Digital Asset Cadre

Miles Fuller served as one IRS Counsel's leading experts on digital asset taxation — coordinating and training attorneys and technical experts that advised IRS field employees on cryptocurrency legal issues, examination techniques, tax computations, and examination development. He worked on various elements of guidance and policy issues, focusing on his understanding of distributed ledger technology to provide practical insights and approaches to tax issues. That knowledge now works for you.

  • Cryptocurrency gains, losses & cost basis disputes
  • NFT and digital collectible characterization
  • DeFi, staking, lending, and yield farming income
  • Hard fork, airdrop, and protocol change treatment
  • Mining and validator income matters
  • IRS John Doe summons responses
  • Crypto bankruptcy tax issues (FTX, Celsius, Voyager)
  • International reporting — FBAR, FATCA, offshore exchanges
  • §6045 broker reporting compliance & dispute response
Legislative Tracker
Track Pending Crypto Tax Bills — 119th Congress →
The enforcement landscape
§6045
New broker reporting rules create IRS information matching on digital asset sales — discrepancies will trigger examinations beginning with 2025 returns
IRS CI
IRS Criminal Investigation has dedicated blockchain tracing resources and is actively pursuing digital asset tax enforcement, including the first crypto tax charges in 2024
JDS
John Doe Summonses to exchanges have given the IRS millions of taxpayer records — cross-referencing against filed returns is ongoing
Form
1099-DA
New digital asset information return creates expanded audit trail — taxpayers need counsel who understands what the IRS can now see
About

Miles B. Fuller

Attorney at Law · Federal Tax Controversy · Digital Assets

Miles Fuller is a federal tax controversy attorney with more than 15 years of experience as a Senior Counsel in the IRS Office of Chief Counsel. During his tenure, he tried cases in United States Tax Court across a broad range of substantive and procedural tax issues. He also served as a Special Assistant United States Attorney in the Federal Districts of Colorado and New Mexico, representing the United States in bankruptcy courts with respect to tax claims.

Miles has advised on and litigated cases relating to conservation easements, microcaptive insurance arrangements, individual retirement accounts, economic substance, collection matters, civil fraud, and cryptocurrency. Miles played a key role in helping the IRS's civil examination function establish its digital asset enforcement program. After leaving IRS Counsel, Miles served as Sr. Director of Government Solutions at Taxbit, a leading digital asset tax compliance company, advising government agencies and industry on digital asset tax reporting and policy before founding his own practice. He has continued to work with the IRS and governments around the world to better understand how to investigate cryptocurrency matters, train individuals, and develop pragmatic tax policy.

Miles has been quoted in Bloomberg Tax, Bloomberg Law, Tax Notes, Fortune, Business Insider, CoinDesk, the Journal of Accountancy, and dozens of other outlets on digital asset and other complex tax matters. He has spoken at various bar association conferences and lectured on digital asset and other tax issues.

Miles earned his Juris Doctor, cum laude, and Master of Business Administration from Chapman University.

Admitted United States Tax Court · California · Colorado (federal tax only — full admission pending)
Education J.D., cum laude — Fowler School of Law, Chapman University · M.B.A. — Argyros College of Business & Economics, Chapman University
LinkedIn linkedin.com/in/miles-fuller-761333224
X / Twitter @mfullerlaw
Miles Fuller, Attorney at Law
Litigation

Notable
Representations

Selected Tax Court opinions from Miles Fuller's tenure as IRS Senior Counsel, spanning conservation easements, retirement accounts, collection due process, and complex financial arrangements.

Samueli v. Commissioner, 132 T.C. 37 (2009) (interpreting the risk requirements applicable to securities transfers under § 1058)
Samueli v. Commissioner, 132 T.C. 336 (2009) (addressing validity of a partner's administrative adjustment request under TEFRA)
Boltar, L.L.C. v. Commissioner, 136 T.C. 326 (2011) (addressing exclusion of expert testimony valuing a conservation easement donation)
Mitchell v. Commissioner, 138 T.C. 324 (2012) (addressing application of the mortgage subordination requirement to a conservation easement donation)
Legg v. Commissioner, 145 T.C. 344 (2015) (addressing timing of § 6751(b)(1) supervisory approval of penalties)
Mazzei v. Commissioner, 150 T.C. 138 (2018) (application of the substance-over-form doctrine to a Roth IRA–FSC arrangement)
Begay v. Commissioner, T.C. Memo. 2013-17 (constitutional challenge to child tax credit requirements)
Roth v. Commissioner, T.C. Memo. 2017-248 (addressing timing of § 6751(b)(1) supervisory approval of penalties)
Wells v. Commissioner, T.C. Memo. 2018-11 (capitalization versus expensing of rehabilitation expenditures on a ranching property)
Richlin v. Commissioner, T.C. Memo. 2020-60 (collection due process case involving procedural and payment application issues)
Mazzei v. Commissioner, T.C. Memo. 2022-43 (award of litigation costs under § 7430)
Zia-Ahmadi v. Commissioner, T.C. Summ. Op. 2017-39 (income and expense reconstruction for a multi-tiered business entity structure)
Influence

Widely Cited.
Frequently Heard.

Recognized as one of the foremost authorities on digital asset taxation — quoted by leading legal and financial press, and a featured speaker at major tax, government, and industry conferences worldwide.

Media & Press
  • Bloomberg Tax & Bloomberg LawMultiple features on crypto tax enforcement & regulation
  • Tax Notes FederalCo-Author — Ethereum's Merge tax analysis; staking positions
  • CoinDeskAuthor & repeated expert — FIFO/specific ID, NFT taxation, staking
  • Fortune & Business InsiderFTX bankruptcy tax implications
  • Journal of AccountancyForm 1099-DA, digital asset final regs
  • CNN, TechCrunch, NerdWalletCrypto tax guidance for consumers
  • Bloomberg Markets (TV)November 2022 — FTX collapse coverage
  • CoinDesk TVMultiple appearances, 2023–2024
Selected Speaking
  • American Bar Association Tax Section2022, 2023, 2024 — Digital Assets & Blockchain; Crypto Staking
  • Chainalysis Links NYC & Trace DC2024 — Crypto Tax Policy & Enforcement
  • Digital Assets at DukeFebruary 2025 — Current Issues in Digital Asset Taxation
  • Florida Bar AssociationJanuary 2026 — Crypto Policy & Practice
  • IAFCI Crypto Summit2026 — Crypto Investigations
  • Token Summit, LiechtensteinKeynote — U.S. Tax Treatment of Digital Assets
  • Crypto Tax Summit, MiamiKeynote — Digital Asset Taxation
  • FTA State Tax Conference2024 — Crypto From A to Z
Contact

Begin with a
Consultation

Tax disputes are time-sensitive. IRS notices carry response deadlines, and the window to preserve your rights — particularly in digital asset matters — can close quickly. Contact the office to schedule an initial consultation.

Email info@mfullerlaw.com
Phone 720.295.9550
LinkedIn linkedin.com/in/miles-fuller-761333224
X / Twitter @mfullerlaw
Address 6140 S. Gun Club Rd., Suite K6-358
Aurora, CO
Focus Federal Tax Controversy & Digital Assets
Admitted U.S. Tax Court · California · Colorado (admission pending)