No Deduction for Decline in Cryptocurrency Value

One investor who bought a cryptocurrency at $1 per unit and it declined to a penny a unit by the end of the year. He asked the IRS whether he could deduct a loss due to worthlessness or abandonment and the IRS said no (Chief Counsel Advice 202302011). There was no worthlessness or abandonment here. While the value of the cryptocurrency was minimal, there was still some value. And he never abandoned the holding. There must be some “express manifestation of abandonment” when an intangible property interest is purported to be abandoned. He maintained ownership, so no loss deduction was allowed.