Constitution Index · S.J.Res. 3 · 2025-01-21

A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to "Gross Proceeds Reporting by Brokers That Regularly Provide Services Effectuating Digital Asset Sales".

Latest official status (2025-03-12): Message received in Senate: Returned to the Senate pursuant to the provisions of H.Res. 212.

Official source ↗

Constitutional grade

A

Constitutional

SJRES 3 is constitutional. It uses lawful congressional authority under Article I to nullify an IRS rule that expanded federal surveillance of decentralized transactions, thereby protecting Fourth Amendment privacy, individual sovereignty, and Tenth Amendment decentralization. The SI analysis finds no rights infringement or power overreach in the disapproval itself.

Article I Amendment IV Amendment X Article I, Section 8, Clause 1 Article I, Section 8, Clause 18 Amendment I Amendment V

SI-generated grade · passed automated checks (real Constitution citation, language rules) · not individually reviewed by a person · methodology · Report an error: hello@valuesforamerica.com

The five checks

Enumerated powers · passes

Congress has explicit authority to enact this disapproval. Article I, Section 8, Clause 1 grants power to lay and collect taxes and to legislate regarding revenue administration, and Article I, Section 8, Clause 18 (Necessary and Proper Clause) supports oversight of agencies implementing tax law. The Congressional Review Act, chapter 8 of title 5, United States Code, provides the statutory mechanism. Disapproving an ultra vires agency rule is squarely within enumerated legislative power.

Bill of Rights · passes

This resolution restores protections under the First Amendment (freedom of association in peer-to-peer transactions) and the Fourth Amendment (freedom from unreasonable searches). The underlying IRS rule would have compelled mass third-party reporting on decentralized financial transactions without individualized suspicion, implicating Fourth Amendment privacy interests and First Amendment associational privacy. Nullifying it removes, rather than creates, a rights infringement.

Individual liberty · passes

This resolution expands individual sovereignty rather than restricting it. It relieves persons using decentralized protocols and developers providing software interfaces from compelled reporting of others' gross proceeds to the IRS. No restriction is placed on person, property, speech, labor, or belief; the burden the underlying rule placed on private action without compelling constitutional justification is removed.

Decentralization · passes

Passes all four questions. Individuals can handle their own tax reporting without deputizing DeFi software intermediaries as federal agents; local and state authorities can enforce fraud without a federal dragnet; and this action de-consolidates power by returning decision-making downward from the federal executive to Congress and to individuals under the Tenth Amendment.

Due process and takings · passes

No bypass of procedural or substantive due process and no taking under the Fifth Amendment Takings Clause. The resolution imposes no penalty, seizure, or deprivation of property, and requires no hearing because it takes nothing. It cures a due process concern in the underlying rule, which imposed compliance costs and potential penalties on persons lacking custody or information, arguably arbitrary government action under the Fifth Amendment Due Process Clause.

Provenance

Grade ID
220
Rubric version
vfa-constitutional-grade/1.0
Graded
2026-10-08 10:50 UTC
Engine
primary SI engine
Source fetched
2026-10-08 09:43 UTC
Source SHA-256
4ed53852f96d581c99421150ca95b19fded7ce5519e37cbcbab44aaf217c81c6
Checks
si-editorial-standard/1.0: real Constitution citation, language rules

Version history · never overwritten

GradeGradedRubric Source hashStatus
A · #220 2026-10-08 vfa-constitutional-grade/1.0 4ed53852f96d current

Cite this

Values for America. “Constitutional grade: S.J.Res. 3, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to "Gross Proceeds Reporting by Brokers That Regularly Provide Services Effectuating Digital Asset Sales"..” VFA Constitution Index, grade 220 (rubric vfa-constitutional-grade/1.0), graded October 8, 2026. https://www.valuesforamerica.com/constitution-index/grades/220. Accessed 2026-10-19.

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