01Letter 2205-A tells you your return has been selected for examination and gives you the examiner's contact details.02Everything before this letter in our series was automated matching. This is different: a revenue agent will ask questions, request documents, and remember answers.03You have the right to be represented — and to have the representative speak for you from the first phone call onward.
Why the first phone call matters
An examination is a records contest conducted through conversation. The examiner's opening call typically sets the scope — which years, which issues, which documents — and everything said in it is part of the file. Answers given casually ("oh, I had a few wallets back then") expand scope; answers given precisely keep it narrow. This is not a reason to be evasive. It is the reason the conversation should be had by someone who does examinations for a living, on your written authorisation (Form 2848), while you say nothing at all.
Nothing in an examination is off the record. Plan every sentence as if it will be quoted back — because it can be.
What a digital-asset examination looks at
The predictable set: completeness of reported disposals against broker and chain data; basis substantiation for every lot — the same records the 1099-DA reconciliation produces; income events (staking, rewards, airdrops) against wallet history; and the foreign-account questions from line 07 of the schedule. An examiner who receives an organised reconciliation file examines a reconciliation. One who receives shoeboxes examines you.
What to do this week
- Do not call the examiner yet. Note the contact details and the response date. Contact deadlines are met by your representative as easily as by you.
- Engage representation and sign Form 2848. An EA, CPA or attorney with examination experience — for digital assets, one who has done basis reconstruction before.
- Assemble the record before anyone talks. Returns as filed, broker forms, exchange exports, wallet histories, the reconciliation file. Gaps found now are explained on your terms; gaps found by the examiner are explained on theirs.
- Map the other years. If reconstructing records reveals unreported earlier activity, the disclosure question just became urgent — and it must be decided with counsel before it surfaces in the exam.
- Check for siblings. A 6173 or CP-series notice in the same period changes the posture. Bring every letter to the first meeting with your representative.
The honest expectations
Most examinations end in one of three ways: no change, an agreed adjustment, or an unagreed adjustment that moves to Appeals and, if unresolved, to a statutory notice of deficiency. Which of the three you get correlates strongly with the state of your records on day one. That part — unlike the selection of your return — is still in your control.
If you have received this letter, an examination is open and contact deadlines apply. This page explains the letter; it does not respond to it, and reading it creates no professional relationship.