Digital-asset matters · National preparation support

Digital-Asset Valuation Records: Dates, Units and Source Assumptions

Keep valuation dates, asset identifiers, units and price sources explicit when preparing financial records for counsel.

By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026

Request a Private Case Review · (646) 588-8182

Identify what the figure measures

A transaction value, account balance, tax figure and proposed sentencing amount can answer different questions. Record the purpose, date and source of each. IRS recordkeeping guidance illustrates why transaction dates, units and contemporaneous values matter for tax records; it does not determine a criminal sentencing calculation.

Make the valuation inputs visible

Identify the asset, network or contract where relevant, number of units, valuation time and price source used by the preparer. Preserve the original calculation and any limitations. Do not silently substitute today’s market price for a historical figure or treat an informal estimate as an expert valuation.

Keep illiquidity and restrictions documented

If records identify trading restrictions, withdrawal limits or an unavailable market, preserve that evidence and the relevant dates. Counsel and qualified financial experts determine its significance. A quoted price may not resolve every question about realizable value; a preparation summary should expose the assumption rather than conceal it.

Track revisions and disagreements

Keep each calculation version and the reason documented for a change. List disagreements between sources without choosing a preferred answer simply because it produces a lower total. SAG can organize the source index and review questions, but does not provide valuation or sentencing-loss opinions.

Continue your preparation

Does a tax valuation automatically set sentencing loss?

No. Preserve the calculation and its purpose. Counsel evaluates the applicable legal rules and qualified experts address financial questions.

Sources and a defined preparation assignment

Official context: IRS: Digital assets and transaction records. Sources checked November 6, 2026. Tax recordkeeping guidance does not determine criminal liability or sentencing loss. Counsel evaluates the applicable law, dates and individual facts.

Work directly with Joseph to define the scope, authorized recipients and review dates. Agreed deliverables can include a personal and professional chronology, indexed supporting records, factual questions for counsel and a practical preparation schedule. SAG does not manage legal responses or provide forensic tracing or valuation opinions. An engagement does not automatically establish privilege.

SAG serves clients nationwide from New Jersey, with travel arranged for cases. SAG is not a law firm. No charging decision, sentence, placement or release date is guaranteed.

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