[gamblor956]

This just addresses the tax consequences. Theft is something else.

The ruling is basically saying that if your exchange didn't support the fork, you didn't receive any crypto, so there's no taxable income.

But if your exchange did support the fork, you have taxable income once those crypto show up in your exchange account and you can transact with them.

[Legogris]

Isn't it rather that you have taxable capital gains once you choose to transact those assets?

[nullc]

That might be a reasonable position to take: it would nicely avoid the issue that you might not know or be able to know about the fork, that the value at the instant of creation is exceptionally unclear, and it would nicely avoid the issue that you might not meaningfully have access to the coins.

The ruling appears to say nothing like that and nothing that would particularly support that interpretation.