The Tax Lawyer Blog: Topical thinking from the lawyers at Moskowitz, LLP

Taxpayer Win: Failure to File Accurate Fbar Deemed Not Willful, Part Ii

Posted on July 19, 2018February 13, 2019 by moskowitz 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...

Meet Our Newest Attorney

Posted on July 17, 2018October 12, 2020 by moskowitz Tax Planning & Compliance, Tax: Audits, Litigation & Collection,

We are pleased to announce the addition of Tyson Smith as Associate Attorney with Moskowitz LLP. We are honored to welcome Tyson to the team at Moskowitz LLP, and fully expect that he will continue to use the experience, skill and work ethic he has demonstrated since joining our firm to...

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

Posted on July 13, 2018February 13, 2019 by moskowitz 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...

Government Regulation of Cryptocurrency

Posted on June 15, 2018February 13, 2019 by moskowitz Tax: Audits, Litigation & Collection, Cryptocurrency Tax Assistance,

Governments throughout the world have begun developing regulations for cryptocurrency exchanges. In this post, we will provide an overview of how various U.S. government agencies view cryptocurrencies and what they are doing to prevent their misuse. The Internal Revenue Service Digital currency = property In 2014, the IRS issued Notice...

1031 Exchange Tax Audits

Posted on May 16, 2018February 13, 2019 by moskowitz Real Estate Law, Tax Planning & Compliance, Tax: Audits, Litigation & Collection,

1031 exchanges are among the most closely scrutinized tax issues for auditors – they are widely used and frequently misused, with many investors running afoul of the rules. In this blog post, we will outline the main reasons for most 1031 audits, and what to look out for under the...

Cryptocurrency Holders: Avoid a Tax Audit!

Posted on May 11, 2018February 13, 2019 by moskowitz Tax: Audits, Litigation & Collection, Cryptocurrency Tax Assistance, Tax Planning & Compliance,

The recent Coinbase, Inc. case marks the beginning of a new phase in IRS investigations, and U.S. taxpayers should beware that our government is unlikely to relinquish its pursuit of digital currency holders. This won't show. The IRS’s success in identifying and pursuing people with foreign accounts has forever changed...

Irs Focus: Tracking Cryptocurrency

Posted on May 9, 2018February 13, 2019 by moskowitz Tax: Audits, Litigation & Collection, Criminal Tax Law, Cryptocurrency Tax Assistance, Tax Planning & Compliance,

In our recent blogs on the new Internal Revenue Service – Criminal Division (IRS-CI) priorities, we noted that new IRS-CI director John D. Fort has placed his department on high alert for tax fraud involving bitcoin and other digital currencies. Here, we discuss U.S. taxpayer noncompliance and various cryptocurrency tax...

2018 Priorities of the Irs Criminal Investigation Division (irs-ci):
part Ii, Two New Initiatives for Identification and Investigation of Tax Crimes

Posted on May 4, 2018November 10, 2020 by moskowitz Cryptocurrency Tax Assistance, Tax Planning & Compliance, Tax: Audits, Litigation & Collection,

This is a continuation of the first post on the 2018 IRS Criminal Investigation Division. Despite the reduction in its budget, the IRS Criminal Investigation Division (IRS-CI) has begun to implement two new initiatives that hope to improve the department’s already impressive success rate. Last year, the IRC-CI made 2,251...

2018 Priorities of the Irs Criminal Investigation Division (irs-ci):
Part I, Types of Cases

Posted on May 1, 2018November 10, 2020 by moskowitz Tax Planning & Compliance, Cryptocurrency Tax Assistance, Tax: Audits, Litigation & Collection,

Following his appointment as new Chief of the IRS Criminal Investigation Division (IRS-CI), John D. Fort announced the 2018 priority areas for IRS-CI enforcement. These goals include pursuit of specific areas of suspected taxpayer noncompliance as well as the implementation of new techniques for identification and investigation. In this post,...

The 2018 Irs Dirty Dozen,
part Iv: Tax Return Preparer Fraud

Posted on April 12, 2018February 14, 2019 by moskowitz Criminal Tax Law, Tax Planning & Compliance, Tax: Audits, Litigation & Collection,

Other Posts in this Series Part I: Identity Theft, Phone and Phishing Scams, Fake Charities Part II: Padding Deductions, Claiming Undeserved Business Credits, Falsifying Income, Inflating Refunds Part III: Abusive Tax Shelters, Offshore Tax Schemes, and Frivolous Tax Arguments Tax return preparer fraud gets its own place on the IRS...

The 2018 Irs Dirty Dozen,
part Iii: Abusive Tax Shelters, Offshore Tax Schemes, and Frivolous Tax Arguments

Posted on April 10, 2018February 14, 2019 by moskowitz Tax Planning & Compliance, Criminal Tax Law, Tax: Audits, Litigation & Collection,

Other Posts in this Series Part I: Identity Theft, Phone and Phishing Scams, Fake Charities Part II: Padding Deductions, Claiming Undeserved Business Credits, Falsifying Income, Inflating Refunds Part IV: Tax Return Preparer Fraud In this post we continue our coverage of tax evasion schemes with three that make it to...

The 2018 Irs Dirty Dozen,
part Ii: Padding Deductions, Claiming Undeserved Business Credits, Falsifying Income, Inflating Refunds

Posted on April 5, 2018February 14, 2019 by moskowitz Tax Planning & Compliance, Criminal Tax Law, Tax: Audits, Litigation & Collection,

Other Posts in this Series Part I: Identity Theft, Phone and Phishing Scams, Fake Charities Part III: Abusive Tax Shelters, Offshore Tax Schemes, and Frivolous Tax Arguments Part IV: Tax Return Preparer Fraud In our last post, we covered four schemes aimed at taking advantage of well-meaning taxpayers. The next...

The 2018 Irs Dirty Dozen,
part I: Identity Theft, Phone and Phishing Scams, Fake Charities

Posted on April 3, 2018February 14, 2019 by moskowitz Criminal Tax Law, Tax Planning & Compliance, Tax: Audits, Litigation & Collection,

Other Posts in this Series Part II: Padding Deductions, Claiming Undeserved Business Credits, Falsifying Income, Inflating Refunds Part III: Abusive Tax Shelters, Offshore Tax Schemes, and Frivolous Tax Arguments Part IV: Tax Return Preparer Fraud Every year, the IRS releases a list of 12 schemes that are especially popular during...

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