However, the new FASB policy combined with the CAMT liabilities created unintended consequences, Lummis and Moreno wrote. Namely, if a firm's bitcoin holdings appreciated, it looks good on paper, but creates a tax liability on their unrealized gains, the person familiar said. As a result, firms like Strategy — and lawmakers like Lummis and Moreno — are lobbying the IRS for exemptions to mitigate this potential burden, similar to those granted for unrealized stock gains held by companies like Berkshire Hathaway.