Tax Controversy & Digital Assets · Chicago, Illinois

The IRS is not
always right.
How you respond
matters.

Big Law discipline. Boutique attention. Built for what crypto enforcement has become.

The IRS is using blockchain analytics, issuing CP2000 notices at scale, and matching 1099-DA data with increasing precision. This isn't the Wild West anymore. It requires the kind of disciplined, substantive advocacy that comes from real tax controversy experience — not just crypto familiarity.

Book a $500 Consultation What I Handle
Michigan Law J.D. Latham & Watkins Baker & McKenzie Thompson Coburn Seyfarth Shaw

Tax season 2026: CP2000 notices for crypto are surging. You have 60 days from the notice date to respond. Don't wait.

Digital Asset Tax Controversy

IRS notices I handle

Every notice requires a different strategy. The wrong response — or no response — can lock in a position that's hard to walk back. Here's what I handle.

Most Common

CP2000
Underreporter Notice

The IRS matched your exchange data against your return and found a discrepancy. Often triggered by 1099-DA gross proceeds reported without cost basis. Most proposed deficiencies are overstated — sometimes dramatically.

Required Response

Letter 6173

Unlike informational letters, this one requires a response. You must either file amended returns, provide documentation confirming correct reporting, or explain your position in writing. Ignoring it invites escalation.

Informational Warning

Letters 6174
& 6174-A

The IRS is telling you they have information about your crypto accounts. No response required — but the underlying compliance issue is real. Receiving one means you're on their radar.

Examination

IRS Audit —
Digital Assets

A full examination of your digital asset activity. Requires organized documentation, clear legal positions, and an advocate who understands how the IRS evaluates crypto transactions — including DeFi, NFTs, and staking.

Penalty Defense

Accuracy-Related
Penalties

The IRS proposes a 20% penalty on top of the tax. Most people pay it without questioning it. Reasonable cause, substantial authority, and first-time abatement are all grounds to eliminate it — if you raise them correctly.

Prior Year Exposure

Voluntary
Disclosure

Unreported crypto from prior years carries real risk. Coming forward proactively — before the IRS finds it — is almost always the better outcome. Attorney-client privilege protects the conversation. A CPA cannot offer that.

About Rita D. Abro

Big Law training.
Boutique focus.

Rita D. Abro

"The IRS enforcement landscape has matured. So has the need for advocates who understand it."

I'm a tax controversy attorney, and I'm now taking cryptocurrency cases — deliberately.

After nearly a decade in Big Law, I've spent my career doing exactly what crypto holders now need most: building and defending positions before the IRS, understanding how examinations are conducted, and knowing what a strong response looks like — and what a weak one costs you.

The digital asset enforcement landscape has changed. The IRS is no longer guessing. Taxpayers need advocates who understand both the law and how the IRS builds its cases. That's the gap I'm filling.

I founded RD Abro Legal in 2018 after my Big Law career, and serve as outside general counsel to financial firms. I am now expanding my practice to digital asset controversy — where institutional-quality advocacy is most needed and least available.

Michigan Law, J.D. University of Michigan Law School, 2006
Latham & Watkins LLP Associate, M&A and Tax
Baker & McKenzie LLP Associate — Fortune 500 & Fortune 50 tax advisory
Thompson Coburn LLP Lead Tax Controversy Associate
Seyfarth Shaw LLP Senior Tax Associate
RD Abro Legal LLC Founder & Managing Attorney, 2018–Present

"Once you respond to the IRS, that response is on the record. Your first position becomes your position. Know what you're dealing with before you write a single word."

— Rita D. Abro, RD Abro Legal LLC

How It Works

From notice to resolution

01

Initial Consultation

$500 flat fee. We review your notice, assess the IRS's position, analyze your records, and tell you exactly what kind of response your situation requires — and whether you need representation to do it.

02

Records & Analysis

We gather your exchange records, transaction history, cost basis documentation, and any prior filings. The strength of your defense is directly proportional to the quality of your documentation.

03

Build the Response

We prepare a substantive written response addressing each element of the IRS's proposed adjustment — basis corrections, non-taxable transfer exclusions, penalty abatement, and corrected calculations.

04

Submit & Advocate

We submit the response on your behalf and manage all IRS communication. If the matter requires escalation to Appeals or Tax Court, we continue the representation at every stage.

Outside General Counsel

Institutional counsel.
Without the overhead.

Since 2018, I have served as retained outside general counsel to financial firms that need Big Law expertise without Big Law billing rates or institutional conflicts.

I also serve as tax co-counsel to law firms requiring specialized expertise on complex transactions — private equity structures, M&A tax planning, corporate reorganizations, and international tax compliance.

If your firm needs a senior attorney on call without the overhead of a full-time hire, that's exactly what I built this practice to provide.

Discuss a Retainer
Regulatory Compliance
Corporate Governance
M&A Tax Planning
PE Fund Structures
Corporate Reorganizations
International Tax
Transaction Advisory
Tax Co-Counsel
Book a Consultation

Before you write a single
word to the IRS.

A $500 flat-fee consultation tells you exactly where you stand — what the IRS is actually alleging, what your records need to show, and what kind of response your notice requires.

$500 · 30-Minute Flat-Fee Consultation · Chicago / Remote

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Attorney-Client Privilege applies from the first conversation.
Licensed in Illinois · RD Abro Legal LLC · Chicago