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Figure 11. IRS Enforcement Frictions and Systemic Effects Under Mainstream Crypto Payment

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Mendeley Data2026-07-03 收录
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This figure presents a policy-facing matrix examining how mainstream cryptocurrency or stablecoin payment may create IRS enforcement and reporting friction even where the underlying transactions are lawful, voluntary, and commercially ordinary. The figure is derived from §IX.F and Table 14 of The Legal Tender Closure Gap Doctrine: Private Crypto Settlement, Transactional Use, and the Limits of Securities and Commodities Classification. It illustrates the doctrine’s neutral enforcement claim: the issue is not presumed illegality; the issue is whether private settlement volume can outpace public reporting and enforcement architecture. The matrix identifies seven enforcement frictions: wallet attribution disputes, underreporting risk, taxpayer-identity mismatch, valuation disputes, audit complexity, delayed compliance, and reporting-system overload. Each friction is organized across three analytical dimensions: operational concern, reporting/enforcement gap, and systemic effect on the United States. The figure’s central claim is that private crypto settlement may occur before public systems have attributed taxpayer identity, verified dollar value, matched reports, reconstructed taxable character, or enforced reporting obligations. A blockchain record may show that value moved, but the public system may still need to determine who controlled the wallet, who received income, who disposed of property, what value applied, what reporting duty attached, and whether the evidence is sufficient for audit or enforcement. From a tax administration and national-systems perspective, the figure shows how high-volume crypto payment activity across wallets, platforms, stablecoin rails, payment processors, payroll providers, bridges, decentralized applications, and intermediaries may increase the burden on IRS matching, reporting, audit, summons, and evidentiary reconstruction systems. This figure supports the doctrine’s broader argument that mainstream crypto payment should not be analyzed only as a private settlement issue. At scale, digital-asset payment may create a public enforcement-capacity problem: private transactions close quickly across fragmented rails, while the sovereign tax system must later reconstruct identity, valuation, taxable character, reporting status, and legal responsibility.

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2026-05-29
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