Taxpayer Win: Failure to File Accurate FBAR Deemed Not Willful, Part IV

Posted on by Moskowitz LLP Posted in Business Law, Tax Planning & Compliance, Tax: Audits, Litigation & Collection
Other Posts in this Series Part I Part II Part III The story of Arthur Bedrosian, CEO of Lannett Company, Inc., and his Swiss bank accounts shows how a taxpayer’s cooperation with an IRS investigation and the court’s belief in the taxpayer’s honesty can be significant factors in the outcome...
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Taxpayer Win: Failure to File Accurate FBAR Deemed Not Willful, Part III

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Business Law, Tax Planning & Compliance
Other Posts in this Series Part I Part II Part IV Before the Offshore Voluntary Disclosure Program (OVDP), it was rare for a taxpayer to pay penalties when they voluntarily came forward with information regarding their foreign accounts. Most tax practitioners, therefore, recommended that their clients do a “quiet” disclosure,...
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Taxpayer Win: Failure to File Accurate FBAR Deemed Not Willful, Part II

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Business Law, Tax Planning & Compliance
Other Posts in this Series Part I Part III Part IV In Part I, we described the background of Bedrosian v. United States, 3d Cir., No. 17-3525, in which the CEO of a pharmaceutical company was pursued for willful FBAR penalties. The IRS didn’t go after Arthur Bedrosian for his...
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Taxpayer Win: Failure to File Accurate FBAR Deemed Not Willful, Part I

Posted on by Moskowitz LLP Posted in Tax Planning & Compliance, Business Law, Tax: Audits, Litigation & Collection
Other Posts in this Series Part II Part III Part IV The IRS aggressively pursues taxpayers for FBAR noncompliance, but in this case it may have overreached its boundaries. CEO takes bad advice Arthur Bedrosian is currently Chief Executive Officer of Lannett Company, Inc., a manufacturer and distributor of generic...
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Using Software For Your Mileage Logs And Other Business Expenses

Posted on by Moskowitz LLP Posted in Business Law, Tax Planning & Compliance, Tax: Audits, Litigation & Collection
Keeping track of mileage and business expenses for tax purposes can be a hassle for any self-employed person. Fortunately, there are a number of mobile apps that can help you gather and store your business receipts, and can simplify production of records required for tax preparation. Why use an app?...
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Business Owners! Get Ready to Meet with Your Tax Professional

Posted on by Moskowitz LLP Posted in Business Law, Tax Planning & Compliance, Tax: Audits, Litigation & Collection
In our previous blog post we presented a list of tax forms and other documents that taxpayers should bring to their tax professional or accountant’s office for accurate preparation of their individual 1040. In this post, we are going to add more items to that list that are applicable to...
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Attorney General Jeff Sessions Rescinds Cole Memo

Posted on by Moskowitz LLP Posted in Business Law, Tax Planning & Compliance
The 2013 Cole Memo was a significant step forward for the cannabis industry, providing practical and useful guidelines to keep the federal government from pursuing prosecutions in states that have legalized marijuana – guidelines such as harsh penalties for driving under the influence, prohibiting interstate distribution, and establishing a minimum...
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Franchise Tax Board Penalties: Accuracy-Related Penalties, Part III: Substantial Misstatements

Posted on by Moskowitz LLP Posted in Business Law, Tax Planning & Compliance
Other Posts in this Series Part I: The Basics Part II: Negligence We continue our discussion of Franchise Tax Board (FTB) accuracy-related penalties with penalties relating to substantial understatements or misstatements of income and asset values. Substantial understatement of income tax obligations Individual taxpayers who understate their tax liabilities by...
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Franchise Tax Board Penalties: Accuracy-Related Penalties, Part II: Negligence

Posted on by Moskowitz LLP Posted in Business Law, Tax Planning & Compliance
Other Posts in this Series Part I: The Basics Part III: Substantial Misstatements The penalties for negligent errors on your tax return can be high, but they pale in comparison to those imposed if the government (federal and/or state) concludes that your mistakes were intentional. In this post, we are...
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