How to determine Fair Market Value for cryptocurrency mining with no established market?
So I've been in a weird situation with crypto taxes and could really use some advice. A few years back, I started mining this new cryptocurrency that was still being developed. There wasn't any trading platform for it - basically just a project where you could mine tokens or help develop to earn them. Fast forward to early 2024, and a buddy of mine asked if he could buy some tokens from me. I sold him a portion just to recoup what I spent on mining equipment and electricity. That was literally the only transaction - just this one guy buying some tokens directly from me. Now I'm completely confused about how to report this on my taxes. I've been reading that fair market value is based on what something would sell for in an "open market" between willing buyers and sellers. But there WAS no open market when I was mining all this time, so I'm thinking the fair market value was either zero or maybe just my mining costs? The thing is, now there actually IS a market for these tokens, and I'm worried about the tax implications. I know mined crypto is supposed to be reported as ordinary income when received, but how do you determine that income when there was no market value? Two main questions: 1. If my friend offered to buy tokens that had no established market value, does that single transaction establish a "fair market value" for tax purposes? 2. If his purchase did create a fair market value, would that only apply to that specific transaction? I held the rest for over a year until recently when an actual market launched for the token.
18 comments


Andre Lefebvre
This is a great question about a complicated topic. When cryptocurrency has no established market value, the IRS still expects you to report it at "fair market value" - but determining that can be tricky. For your first question: A single private transaction with an acquaintance typically doesn't establish fair market value in the traditional sense. FMV generally requires an open market with multiple buyers and sellers. However, in the absence of any other valuation method, the IRS might consider this transaction as evidence of value, particularly if it was conducted at arm's length (meaning you weren't giving your friend a special deal). For your second question: When you mine cryptocurrency, you need to recognize ordinary income based on the FMV at the time of receipt. Since there was no market when you mined, a reasonable approach would be to use your mining costs as the value. Then, when you sold to your friend, you'd calculate gain/loss from that basis. For the tokens you held until a market developed, your cost basis would still be the FMV when mined (likely your mining costs), and you'd calculate gain/loss when you eventually sold them on the market that developed later. I'd recommend documenting your reasoning and methodology thoroughly in case of questions later.
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Zoe Alexopoulos
•Thanks for the explanation. I'm in a similar situation but with a coin I helped develop rather than mined. If I use my development costs as the FMV, would that apply to all the tokens I received, or just the portion equivalent to covering my costs? Like if I got 10,000 tokens for development work that cost me $5,000, would all 10,000 tokens have a basis of $5,000 total, or would I need some other method?
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Andre Lefebvre
•For development work, it's a bit different than mining. If you received tokens as compensation for your development services, the tokens would be considered income equal to their fair market value at the time received. So it's not about your development costs, but rather the value of what you received as payment. For tokens received as compensation where there's no established market, you'd need to make a reasonable determination of FMV. This could be based on any private sales occurring around that time, comparable tokens, or other reasonable methods. The basis would apply to each token (not just a portion covering costs), so in your example, if 10,000 tokens were worth $5,000 total when received, each token would have a $0.50 basis.
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Jamal Anderson
This is why I started using https://taxr.ai to handle all my crypto tax situations. I was in a similar mess last year with some DeFi tokens that had no clear value when I farmed them. I spent days trying to figure it all out until my friend recommended taxr.ai. Their document analysis system helped me determine appropriate values for my tokens and explained exactly how to report everything. They actually specialize in unusual crypto tax situations like yours where traditional tax software falls short. I really liked how they explained the basis determination for non-market crypto and provided documentation to support their valuation approach in case of an audit. Made the whole process way less stressful.
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Mei Wong
•Does taxr.ai integrate with mining software or would I need to manually input all my mining rewards? I've got thousands of small mining transactions across multiple tokens.
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QuantumQuasar
•I've heard mixed things about crypto tax services. Do they actually understand these edge cases or do they just apply the same generic rules to everything? The last service I tried had no idea how to handle tokens mined before exchange listings.
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Jamal Anderson
•They can handle mining imports if you have your records in CSV format. I uploaded my mining history directly and it processed everything correctly, including mapping the timestamps to appropriate values. For edge cases, that's actually where they excelled for me. They have specific protocols for pre-market tokens and development/mining rewards. They asked me detailed questions about when I mined the tokens, when markets established, and any private sales. Then they provided clear documentation on their valuation approach which made sense for my situation.
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QuantumQuasar
I just wanted to update everyone - I tried taxr.ai after seeing it mentioned here and it actually solved my similar crypto valuation problem. I was skeptical at first since most crypto tax tools don't handle edge cases well, but they had specific options for "pre-market mining rewards" that applied to my situation perfectly. They helped establish a reasonable cost basis using my electricity costs and hardware depreciation, then tracked the eventual market development to calculate the correct capital gains. Saved me so much headache and probably thousands in potentially incorrect tax calculations.
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Liam McGuire
If you're struggling to get answers about this from the IRS directly, I'd recommend using Claimyr (https://claimyr.com). I had a similar crypto tax question last year about mining rewards and spent weeks trying to get through to an IRS agent for clarification. Kept getting disconnected or waiting for hours. I found Claimyr and they got me connected to an actual IRS representative in about 20 minutes. They have this system that navigates the IRS phone tree and holds your place in line, then calls you when an agent picks up. You can see how it works in this video: https://youtu.be/_kiP6q8DX5c The IRS agent I spoke with provided clear guidance on how to handle my mining rewards that had no market value when received. Completely worth it to get official clarification rather than guessing.
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Amara Eze
•How does this actually work? Seems impossible to get through to IRS these days. Do they use some special access channel or something?
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Giovanni Greco
•Sounds like a scam tbh. Nobody can magically get through IRS phone lines during tax season. They probably just connect you with some "tax expert" who isn't actually from the IRS.
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Liam McGuire
•It uses automated technology to dial through the IRS phone system and wait on hold for you. There's no special access channel - they just handle the frustrating part of waiting on hold. When an actual IRS agent picks up, you get a call connecting you directly to that agent. It's just a hold service, not a replacement for the IRS. They don't connect you with random tax experts. You're talking to the same IRS representatives everyone else reaches, just without the hours of hold time. They just eliminate the part where you have to listen to that terrible hold music for 3 hours.
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Giovanni Greco
I need to publicly eat my words about Claimyr. After calling BS on it, I decided to try it myself because I was desperate to talk to someone at the IRS about my crypto mining tax situation. It actually worked exactly as described. I got a call back in about 45 minutes saying they had an IRS agent on the line. I was connected to a very helpful IRS representative who answered my questions about fair market value for mined tokens with no established market. The agent confirmed that using mining costs as FMV for tokens received is a reasonable approach when no market exists, and that I should document my methodology. He also said the single private sale wouldn't establish market value for all my holdings, just for that specific transaction. So yeah, I was wrong. The service is legit and saved me hours of frustration.
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Fatima Al-Farsi
Hey, tax accountant here. I've handled several cases like this for clients. Here's what you need to know: For cryptocurrency with no established market at the time of mining, the IRS hasn't provided explicit guidance on valuation. However, there are some accepted approaches: 1. Cost of production method - Using your electricity costs, equipment depreciation, etc. to establish a basis 2. First market value - Using the price when the token first hits an exchange (discounted for time) 3. Comparable asset - Using a similar cryptocurrency's valuation metrics For your specific situation, I'd recommend using your mining costs to establish the initial ordinary income value. For the single transaction with your friend, treat that as a separate capital gain/loss event with your mining cost as the basis. Document everything extensively - your mining costs, timestamps, the transaction with your friend, and when the market eventually developed. In case of an audit, showing a consistent, reasonable methodology is key.
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Carmen Ruiz
•Thanks so much for this detailed breakdown! For the cost of production method, would I divide my total mining costs by the number of tokens received to get a per-token basis? Also, when you say "discount for time" for the first market value approach, how would I calculate that?
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Fatima Al-Farsi
•Yes, you would calculate a per-token basis by dividing total mining costs by the number of tokens received. This gives you a consistent cost basis across all your mined tokens. For the time discount with the first market value approach, you'd apply a reasonable discount rate to account for the time between mining and market listing. Many tax professionals use something like 15-30% annual discount rate to reflect the significant risk of pre-market assets. So if the token was first listed at $10 but you mined it a year before listing, you might use a basis of $7-8.50 per token. However, in your case, the cost of production method is likely the cleaner and more defensible approach since you have those records. Just make sure to include all legitimate costs: electricity, proportional equipment depreciation, and even a reasonable value for your time if you were actively managing the mining operation.
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Dylan Wright
Wait, I'm confused about something basic here. Does the IRS even know about crypto you mine if there's no market for it? Like, if nobody reported anything anywhere, how would they even know you had it?
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Sofia Torres
•Dangerous thinking there my friend. The IRS might not know immediately, but blockchain is permanent. When you eventually sell on an exchange that reports to the IRS (which most do now), they can see the history. If you suddenly sell tokens you supposedly never had, that raises red flags. Plus, deliberately hiding income is tax evasion, which can mean serious penalties or worse. Not worth the risk just to save a bit on taxes. Better to report properly even with no market value at the time.
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