Joshua Jarrett’s 8,876 New Tezos Cryptocurrency Reward Tokens Are Not Taxable Income: Brief in Support of Jarrett’s Amended Return and Claim for Refund

52 Pages Posted: 3 Jan 2023

See all articles by Abraham Sutherland

Abraham Sutherland

University of Virginia School of Law

Date Written: July 31, 2020

Abstract

Brief in support of Joshua Jarrett’s petition to the IRS seeking to establish that his cryptocurrency “staking rewards” are not taxable income until sold. Upon the IRS’s failure to respond to or rule on this petition, suit was filed in Joshua Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn. 2021).

Includes supporting material submitted with the petition and subsequently published as “Dilution and True Economic Gain From Cryptocurrency Block Rewards,” Tax Notes Federal, Aug. 17, 2020, p. 1213.

Keywords: Tezos, Proof of Stake, Bitcoin, Cryptocurrency, Taxation, Income Tax, Dilution, Block Rewards, Staking Rewards

JEL Classification: K34, K2, E4, E42, G28, H2, H20, H21, H24, H25, K00, L51

Suggested Citation

Sutherland, Abraham, Joshua Jarrett’s 8,876 New Tezos Cryptocurrency Reward Tokens Are Not Taxable Income: Brief in Support of Jarrett’s Amended Return and Claim for Refund (July 31, 2020). Available at SSRN: https://ssrn.com/abstract=4311624 or http://dx.doi.org/10.2139/ssrn.4311624

Abraham Sutherland (Contact Author)

University of Virginia School of Law ( email )

580 Massie Road
Charlottesville, VA 22903
United States

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