Revenue Procedure 2024-28 provided a one-time safe harbor letting taxpayers allocate their pre-2025 crypto cost basis across specific wallets before January 1, 2025, as the IRS moved to mandatory wallet-by-wallet accounting.
The allocation could be done by specific units or by a global allocation method, but it had to be documented before the deadline and applied consistently afterward. Taxpayers who did not allocate are treated under the default rules for each wallet.
Why it matters: the deadline has passed. Anyone who did not document an allocation needs a defensible position on how basis was assigned, which is often the first thing a crypto audit examines. See wallet-by-wallet accounting.
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