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

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 many years of noncompliance with foreign reporting obligations, but rather for...

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

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 medications. In the early days of his career (1970s) he frequently...

Deducting Fertility Treatments: The Morrissey Case, Part II

The Issue Defined In our last post, we described how a taxpayer was not permitted to deduct his significant expenses for fertility treatments involving himself, three egg donors, three gestational surrogates, seven IVF procedures, and two fertility specialists. Here we are going to describe Joseph Morrissey’s main arguments for receiving...