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

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...

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

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...

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...

Cryptocurrency Holders: Avoid a Tax Audit!

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

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...