Research and the regulatory record

Regulations are where tax policy becomes real, and the comment process is where affected taxpayers get a hearing. Our founder has taken that seat at the table on the Form 1099-DA rules, and Digital Asset Tax Action builds its research and education on what that work reveals.

Original research

Study · September 2026 · Docket IRS-2026-0266

Who commented on the IRS Form 1099-DA electronic delivery rule

We pulled all 18 public comments on the proposal to let brokers furnish Form 1099-DA electronically with no paper alternative, read every attachment, and coded each comment by commenter type, position and the issues it raised. Nobody in the docket opposed electronic delivery itself; four of the eighteen filings are off topic; and the provision drawing the most objections is one the preamble never asked about. The coded dataset is published alongside the analysis, with no commenter named.

Read the analysis · Download the coded data (CSV) · Browse the docket

Comment letters and testimony

A note on what this work is: formal comments to Treasury and the IRS address regulations, not legislation. Participating in agency rulemaking is education and regulatory participation — not lobbying — and it is a core part of our educational mission.

And a note on attribution: the submissions below were filed by our founder, Andrew Gordon, through his tax firm, and the public docket credits them that way. We link the official copies so readers can verify the record directly.

Comment letter · May 2026 · Docket IRS-2026-0266

Comments on electronic furnishing of Form 1099-DA (REG-105064-25)

Our founder, Andrew Gordon, submitted a formal comment letter on the proposed regulations (91 FR 10983, published March 6, 2026) governing how brokers furnish Form 1099-DA electronically, filed through his tax firm and signed in his capacity as a tax attorney and CPA. The letter supports electronic delivery while urging Treasury and the IRS to make it genuinely usable: a preserved paper option for low-volume customers, withdrawal-of-consent rights, a machine-readable format alongside the human-readable statement, and a streamlined path back to compliance for non-willful taxpayers.

Read the comment letter in the public docket · Proposed rule in the Federal Register · Browse docket IRS-2026-0266 · Download the comment letter (PDF)

Hearing testimony · July 8, 2026

Public hearing testimony on REG-105064-25

Andrew Gordon was one of two witnesses at the IRS public hearing on the proposed electronic-furnishing regulations, held by teleconference on July 8, 2026. His testimony addressed the cost-basis gap for assets transferred between platforms, taxpayer confusion about basic digital asset taxability, and the absence of a workable remediation path for non-willful taxpayers — because how millions of taxpayers receive these forms affects whether they can actually use them.

Official hearing agenda and speaker list · Outline of testimony · Hearing notice in the Federal Register · Founder’s first-person account of the hearing · Download the testimony (PDF)

Ongoing research

Our research agenda examines how digital asset reporting rules perform in practice: the accuracy of broker-reported data during the basis transition, the compliance burden on taxpayers with small transactions, and the experience of fraud victims within the current loss rules. Where we can build a record from primary sources and publish the data behind it — as in the analysis of the 1099-DA comment docket above — we do. New publications will appear here as they are released.