About Miles B. Fuller
Of Counsel | 53 Tax Law, PLLC
Litigation experience from former IRS counsel.
Miles Fuller is a federal tax controversy attorney with more than 15 years of experience as a Senior Counsel in the IRS Office of Chief Counsel. During his tenure, he tried cases in United States Tax Court across a broad range of substantive and procedural tax issues. He also served as a Special Assistant United States Attorney in the Federal Districts of Colorado and New Mexico, representing the United States in bankruptcy courts with respect to tax claims.
Miles has advised on and litigated cases relating to conservation easements, microcaptive insurance arrangements, individual retirement accounts, economic substance, collection matters, civil fraud, and cryptocurrency. Miles played a key role in helping the IRS's civil examination function establish its digital asset enforcement program. After leaving IRS Counsel, Miles served as Sr. Director of Government Solutions at Taxbit, a leading digital asset tax compliance company, advising government agencies and industry on digital asset tax reporting and policy before founding his own practice. He has continued to work with the IRS and governments around the world to better understand how to investigate cryptocurrency matters, train individuals, and develop pragmatic tax policy.
Miles is based in Colorado where he supports taxpayers in IRS audits and litigation throughout the Denver metro area and across the Rocky Mountain region. But he’s often retained to assist taxpayers nationally and internationally with federal tax issues.
Alongside his continued work with taxpayers in the Denver Metro, Miles has been:
Quoted in Bloomberg Tax, Bloomberg Law, Tax Notes, Fortune, Business Insider, CoinDesk, the Journal of Accountancy
Speaking at various bar association conferences and lectured on digital assets and other tax issues
Teaching as an adjunct professor at the University of Denver, Sturm College of Law
Credentials
J.D., cum laude, Chapman University – Fowler School of Law
M.B.A., Chapman University, Argyos College of Business & Economics
Admitted: United States Tax Court - California & Colorado
Notable Representations
Selected Tax Court opinions from Miles Fuller's tenure as IRS Senior Counsel:
•Samueli v. Commissioner, 132 T.C. 37 (2009)
Samueli v. Commissioner, 132 T.C. 336 (2009)
Boltar, L.L.C. v. Commissioner, 136 T.C. 326 (2011)
Mitchell v. Commissioner, 138 T.C. 324 (2012)
Legg v. Commissioner, 145 T.C. 344 (2015)