At LA Tech Week 2025, I attended a surprising session on crypto mining - surprising because I thought mining was dead after Ethereum moved to proof-of-stake. Turns out, Bitcoin mining is BOOMING again, and many accountants’ clients are getting into it.
The tax and accounting implications are complex, and getting the classification wrong (business vs. hobby) can cost clients tens of thousands in taxes.
The Mining Revival: Why Now?
What I learned at LA Tech Week:
Bitcoin mining is profitable again (October 2025):
- Bitcoin price: ~$67,000
- Mining difficulty: Stabilized after China ban adjustments
- Energy costs: Declining (renewable energy adoption)
- New ASIC miners: More efficient (Antminer S21, Whatsminer M50S+)
Home mining renaissance:
- Small-scale miners (1-5 machines) are back
- “Hobby miners” becoming accidental businesses
- Many don’t understand tax implications
Result: CPAs dealing with clients who have mining income and NO idea how to report it.
Business vs. Hobby: The $50,000 Question
This is THE critical classification issue for mining.
If Mining = Business (Schedule C)
Advantages:
- Deduct ALL ordinary and necessary expenses
- Deduct losses against other income (W-2 wages, investment income)
- Can carry losses forward/backward
- Home office deduction available
- Depreciation on mining equipment (Section 179 immediate expensing)
Disadvantages:
- Self-employment tax (15.3% on net profit)
- Quarterly estimated tax requirements
- More complex record-keeping
- Higher audit risk
If Mining = Hobby (Schedule 1, Line 8)
Advantages:
- No self-employment tax
- Simpler record-keeping
- Lower audit risk
Disadvantages:
- CANNOT deduct expenses (TCJA eliminated misc. itemized deductions)
- CANNOT deduct losses
- All income taxed, zero deductions
- Terrible tax outcome
Example showing the difference:
Mining activity:
- Bitcoin mined: 0.5 BTC
- Value when mined: $33,500
- Electricity costs: $12,000
- Equipment depreciation: $8,000
- Internet, cooling: $1,500
- Total expenses: $21,500
If classified as BUSINESS:
- Gross income: $33,500
- Expenses: $21,500
- Net profit: $12,000
- Self-employment tax: $1,797 (15.3% on $12,000 after SE deduction)
- Income tax (24% bracket): $2,880
- Total tax: $4,677
If classified as HOBBY:
- Gross income: $33,500
- Expenses: $0 (not deductible)
- Net profit: $33,500
- Income tax (24% bracket): $8,040
- Total tax: $8,040
Difference: $3,363 more tax as hobby!
This is why classification matters.
The 9-Factor Test: Business or Hobby?
IRS uses 9 factors to determine business vs. hobby (IRC Regulation § 1.183-2):
Factor 1: Manner in Which Activity is Carried On
Business indicators:
- Maintain complete books and records
- Have business plan
- Separate business bank account
- Business license/permits
- Professional appearance
Hobby indicators:
- Casual record-keeping
- No business plan
- Mix personal and business funds
- No permits
- Amateur approach
My client - BUSINESS:
- Beancount ledger tracking all transactions
- LLC formed for mining operation
- Separate business checking account
- Business license obtained
- Dedicated mining facility (basement converted)
Factor 2: Expertise of Taxpayer
Business indicators:
- Study mining profitability
- Attend conferences (LA Tech Week!)
- Join mining pools professionally
- Hire consultants
- Continuous education
Hobby indicators:
- Casual knowledge
- No research
- Set-it-and-forget-it approach
My client - BUSINESS:
- Attended LA Tech Week mining sessions
- Member of Bitcoin mining forums
- Monitors hashrate, difficulty, profitability daily
- Reads whitepapers on mining optimization
Factor 3: Time and Effort
Business indicators:
- Substantial time devoted
- Active management
- Regular monitoring
- Optimization efforts
Hobby indicators:
- Minimal time
- Occasional check-ins
- Passive activity
My client - BUSINESS:
- Spends 10-15 hours/week on mining operations
- Daily monitoring of hashrate
- Weekly maintenance
- Monthly profitability analysis
Factor 4: Expectation of Asset Appreciation
Business indicators:
- Primary motivation is current income (not Bitcoin price appreciation)
- Would continue even if Bitcoin price stable
- Focus on mining profitability metrics
Hobby indicators:
- Primary motivation is Bitcoin price speculation
- Wouldn’t mine if Bitcoin price drops
- Just holding for appreciation
My client - BUSINESS:
- Sells Bitcoin monthly to cover expenses (not holding for appreciation)
- Mining continues regardless of Bitcoin price
- Focus on operational profitability
Factor 5: Success in Similar Activities
Business indicators:
- Prior business experience (any field)
- History of turning unprofitable ventures into profitable ones
- Business acumen demonstrated
Hobby indicators:
- No business experience
- History of abandoned projects
- No demonstrated business skills
My client - BUSINESS:
- Owns successful consulting business (demonstrates business acumen)
- Turned mining profitable within 6 months
- Applied business principles to mining
Factor 6: History of Income or Losses
Business indicators:
- Profits in some years
- Losses due to startup costs or market conditions (not perpetual losses)
- Trend toward profitability
Hobby indicators:
- Losses year after year with no expectation of profit
- Perpetual losses for 3+ years
- No credible plan to become profitable
My client - BUSINESS:
- Year 1 (2024): Loss of $15,000 (startup costs)
- Year 2 (2025): Profit of $8,000 (operational)
- Trend toward profitability: ✓
IRS Safe Harbor: Profits in 3 of last 5 years = presumed business
Factor 7: Amount of Occasional Profits
Business indicators:
- Substantial profits relative to investment
- Profits exceed losses over time
- ROI comparable to other businesses
Hobby indicators:
- Trivial profits
- Losses far exceed profits
- No realistic ROI
My client - BUSINESS:
- Initial investment: $35,000 (equipment)
- Year 1 loss: $15,000
- Year 2 profit: $8,000
- Projected Year 3 profit: $18,000
- ROI trajectory: Positive
Factor 8: Financial Status of Taxpayer
Business indicators:
- Taxpayer depends on income from activity
- Primary or significant income source
- Taxpayer needs the income
Hobby indicators:
- Taxpayer wealthy with other income sources
- Mining income trivial relative to other income
- Clearly doing it for enjoyment, not income
My client - CAUTION:
- W-2 income: $180,000/year (high earner)
- Mining income: $8,000 (4% of total income)
- Does NOT depend on mining income
This factor weighs AGAINST business classification.
However: This factor alone doesn’t disqualify business treatment. High-income individuals can still have legitimate side businesses.
Factor 9: Elements of Personal Pleasure
Business indicators:
- Activity is tedious, labor-intensive
- Not particularly enjoyable
- Done purely for profit
Hobby indicators:
- Activity is fun, recreational
- Primary motivation is enjoyment
- Would do it even without profit
My client - MIXED:
- Mining itself is NOT fun (noisy, hot, requires maintenance)
- BUT enjoys learning about Bitcoin technology
- Motivation: 70% profit, 30% interest in technology
Overall assessment: 7 of 9 factors favor BUSINESS classification
My Client Case Study: Home Bitcoin Mining
Client: Software engineer, age 35
W-2 income: $180,000/year
Started mining: January 2024
Mining setup:
- 4× Antminer S19 XP miners
- Total hashrate: ~560 TH/s
- Location: Dedicated basement room (500 sq ft)
- Power: 240V dedicated circuits, 14 kW capacity
- Cooling: Industrial exhaust fans + AC
Initial investment (2024):
- Mining equipment: $28,000 (4 miners @ $7,000 each)
- Electrical work: $4,500 (dedicated circuits, safety upgrades)
- Cooling equipment: $2,500
- Mining pool fees (prepaid): $500
- Total: $35,500
Year 1 (2024) Results:
- Bitcoin mined: 0.42 BTC
- Average BTC price when mined: $45,000
- Gross income: $18,900
- Electricity: $16,800 (14 kW × $0.12/kWh × 24 hrs × 350 days)
- Depreciation: $11,200 (MACRS 5-year, 40% year 1)
- Repairs/maintenance: $1,200
- Internet: $720
- Mining pool fees: $945 (5% of proceeds)
- Home office (500 sf of 2,000 sf home): $3,750
- Total expenses: $34,615
- Net loss: ($15,715)
Year 2 (2025, projected):
- Bitcoin mined: 0.35 BTC (difficulty increased)
- Average BTC price: $65,000
- Gross income: $22,750
- Electricity: $17,500 (rate increased to $0.125/kWh)
- Depreciation: $8,960 (MACRS year 2)
- Repairs/maintenance: $800
- Internet: $720
- Mining pool fees: $1,138
- Home office: $3,900
- Total expenses: $33,018
- Net profit: ($10,268) (WAIT - still a loss!)
Revised: Client upgraded to more efficient miners mid-year:
- Additional 2× S21 miners: $15,000
- Increased hashrate to 840 TH/s
- Electricity same (more efficient)
- Additional BTC: 0.15 BTC @ $67,000 = $10,050
- Actual gross income: $32,800
- Actual net profit: $7,282
Tax classification: Schedule C (Business)
Beancount Ledger for Mining Business
Here’s how I’m tracking this client’s mining operation:
Chart of accounts:
; Income accounts
2024-01-01 open Income:Mining:Bitcoin USD
2024-01-01 open Income:Mining:PoolRewards USD
; Asset accounts
2024-01-01 open Assets:Mining:Equipment USD
2024-01-01 open Assets:Mining:AccumulatedDepr USD
2024-01-01 open Assets:Crypto:Bitcoin:Mined BTC
; Expense accounts
2024-01-01 open Expenses:Mining:Electricity USD
2024-01-01 open Expenses:Mining:PoolFees USD
2024-01-01 open Expenses:Mining:Internet USD
2024-01-01 open Expenses:Mining:Repairs USD
2024-01-01 open Expenses:Mining:HomeOffice USD
2024-01-01 open Expenses:Mining:Depreciation USD
Equipment purchase:
2024-01-15 * "Purchase Antminer S19 XP" #mining-equipment
purchase_count: 4
cost_per_unit: 7000.00
total_cost: 28000.00
asset_class: "MACRS_5year"
section_179_eligible: true
Assets:Mining:Equipment 28000.00 USD
Liabilities:CreditCard -28000.00 USD
Monthly mining reward:
2024-10-31 * "Bitcoin Mining Reward - October" #mining-income
btc_mined: 0.035
btc_usd_rate: 68500.00
gross_income: 2397.50
pool_fee_pct: 0.05
pool_fee_usd: 119.88
net_btc_received: 0.03325
Income:Mining:Bitcoin -2397.50 USD
Assets:Crypto:Bitcoin:Mined 0.03325 BTC @ 68500.00 USD
Expenses:Mining:PoolFees 119.88 USD
Monthly electricity:
2024-10-31 * "Mining Electricity - October" #mining-expense
kwh_used: 10080 ; 14 kW × 24 hrs × 30 days
rate_per_kwh: 0.125
mining_portion: 1260.00
household_portion: 120.00
total_bill: 1380.00
Expenses:Mining:Electricity 1260.00 USD
Expenses:Personal:Utilities 120.00 USD
Liabilities:CreditCard -1380.00 USD
Annual depreciation:
2024-12-31 * "Mining Equipment Depreciation - Year 1" #depreciation
equipment_cost: 28000.00
macrs_year1_rate: 0.20 ; 20% for 5-year property
bonus_depreciation: 0.00 ; Not taking bonus
depreciation_amount: 5600.00
Expenses:Mining:Depreciation 5600.00 USD
Assets:Mining:AccumulatedDepr -5600.00 USD
Section 179 election (alternative):
; Instead of MACRS, could elect Section 179 immediate expensing
2024-12-31 * "Section 179 Expensing - Mining Equipment" #section179
equipment_cost: 28000.00
section_179_limit: 1220000.00 ; 2024 limit
amount_expensed: 28000.00
Expenses:Mining:Equipment:Section179 28000.00 USD
Assets:Mining:Equipment -28000.00 USD
Quarterly estimated tax payment:
2025-09-15 * "Q3 2025 Estimated Tax - Mining Income" #estimated-tax
net_mining_profit_ytd: 7282.00
estimated_tax_rate: 0.40 ; Fed + SE + State
q3_payment: 2913.00
Expenses:Taxes:Estimated 2913.00 USD
Assets:Checking -2913.00 USD
Home office deduction:
2025-12-31 * "Home Office Deduction - Mining" #home-office
total_home_sqft: 2000
mining_room_sqft: 500
business_use_pct: 0.25
annual_mortgage_interest: 12000.00
annual_property_tax: 6000.00
annual_insurance: 1800.00
annual_utilities: 3600.00
annual_maintenance: 2400.00
total_home_expenses: 25800.00
business_portion: 6450.00
Expenses:Mining:HomeOffice 6450.00 USD
Assets:Personal:Home:Basis -6450.00 USD ; Reduces home basis
Tax Reporting: Schedule C
Form 1040, Schedule C:
Part I: Income
- Line 1: Gross receipts: $32,800 (Bitcoin mined at FMV)
Part II: Expenses
- Line 8: Depreciation: $8,960
- Line 11: Contract labor: $0
- Line 25: Utilities: $17,500 (electricity)
- Line 30: Home office: $6,450
- Line 48: Total expenses: $33,018
Part III: Cost of Goods Sold
- (Not applicable for mining)
Result:
- Net loss: ($218) → Shows on Schedule 1, Line 3
- Self-employment tax: $0 (no profit)
- Loss reduces other income (W-2 wages)
Tax savings from loss:
- Loss offsets $218 of W-2 income
- Tax savings: $78 (24% bracket × $218)
But this is Year 2 - showing path to profitability.
The Self-Employment Tax Surprise
Clients often don’t realize mining income = self-employment income.
If mining net profit = $20,000:
Self-employment tax calculation:
- Net profit: $20,000
- SE tax rate: 15.3% (12.4% Social Security + 2.9% Medicare)
- SE tax deduction: $1,413 (50% of SE tax)
- Taxable SE income: $18,587
- SE tax: $2,826
Plus regular income tax:
- $20,000 ordinary income at 24% bracket: $4,800
- Total tax: $7,626 (38% effective rate)
Many clients shocked by this.
Equipment Depreciation: MACRS vs. Section 179
Critical tax planning decision:
MACRS (Modified Accelerated Cost Recovery System)
5-year property for mining equipment
Depreciation schedule (for $28,000 equipment):
- Year 1: 20% = $5,600
- Year 2: 32% = $8,960
- Year 3: 19.2% = $5,376
- Year 4: 11.52% = $3,226
- Year 5: 11.52% = $3,226
- Year 6: 5.76% = $1,613
Pros:
- Spreads deduction over 6 years
- Matches economic depreciation
- Preserves Section 179 for other assets
Cons:
- Slower tax benefit
- Risk that mining becomes unprofitable before fully depreciated
Section 179 Immediate Expensing
Expense up to $1,220,000 (2025 limit) in Year 1
For $28,000 equipment:
- Year 1: 100% = $28,000
- Years 2-6: $0
Pros:
- Immediate tax benefit
- Larger Year 1 loss (can offset W-2 income)
- Accelerates deductions before law changes
Cons:
- Uses up Section 179 limit
- If mining income low, “wastes” deduction (can’t carry forward)
- Recapture if sell equipment or convert to personal use
My recommendation for most clients: Section 179 if:
- Have other income to offset (W-2, business income)
- Equipment expensive ($20K+)
- Want immediate cash flow benefit
Use MACRS if:
- Mining income high enough to use depreciation
- Want to preserve Section 179 for other assets
- Expect mining to continue 5+ years
The Hobby Loss Rules: What Triggers Audit?
IRS looks for patterns suggesting hobby, not business:
Red flags:
- Losses every year for 5+ years (no profitability)
- High W-2 income with mining losses (tax shelter appearance)
- Expensive equipment disproportionate to income generated
- No business plan or records
- Activity looks recreational (GPU gaming rigs “also used for mining”)
- No separate business bank account
- Mining income trivial ($500/year) but claiming $5,000 expenses
How to avoid audit:
-
Maintain detailed records:
- Beancount ledger (or equivalent)
- Receipts for all expenses
- Business plan with profitability projections
- Time logs showing hours devoted
-
Separate business from personal:
- Dedicated mining space (not gaming room)
- Business bank account
- Business credit card
- LLC or sole proprietorship
-
Show profit motive:
- Sell Bitcoin to cover expenses (not just HODLing)
- Adjust operations to increase profitability
- Shut down if unprofitable (or document reasons for continuing)
-
Be profitable in 3 of 5 years:
- Safe harbor presumption
- Losses in startup years acceptable
- But must show trend toward profit
Questions for the Community
-
For accountants: How are you advising clients on business vs. hobby classification for small-scale mining (1-2 machines)?
-
For tax pros: Section 179 vs. MACRS for mining equipment - what’s your default recommendation?
-
For Beancount users: How are you tracking the electricity allocation between mining and personal use?
-
Has anyone had mining clients audited? What did IRS focus on?
-
For everyone: With Ethereum now proof-of-stake, is GPU mining (altcoins) ever profitable enough to justify business treatment?
My Bottom Line
Crypto mining taxation is complex:
- Business vs. hobby classification is critical ($3,000+ tax difference)
- Self-employment tax surprises clients (38% effective rate)
- Equipment depreciation requires planning (MACRS vs. Section 179)
- Home office deduction valuable but requires documentation
- Record-keeping essential for audit defense
My standard advice:
- Treat as business if serious and profitable (or path to profitability)
- Maintain meticulous records (Beancount ledger)
- Separate business from personal completely
- Pay quarterly estimated taxes
- Plan for self-employment tax (not just income tax)
The LA Tech Week mining discussion convinced me: Bitcoin mining is back, and accountants need to understand the tax implications.
Alice Thompson, CPA
Thompson & Associates
P.S. - I’ve created a “Mining Business Classification Worksheet” (9-factor analysis) and “Mining Business Beancount Template” for clients. If there’s interest, happy to share.
Key Sources:
- LA Tech Week 2025 (October 13-19)
- IRC Regulation § 1.183-2 (Activity not engaged in for profit)
- IRS Publication 535 (Business Expenses)
- IRC § 179 (Election to Expense Depreciable Assets)
- MACRS depreciation tables (IRS Publication 946)