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Attorney Client Privilege

U.S. Justice Dept reviewing Panama documents

U.S. Justice Dept reviewing Panama documents

WASHINGTON (Reuters) – The U.S. Justice Department is reviewing the leaked documents from a Panamanian law firm that reveal the offshore financial arrangements of global politicians and public figures, a department spokesman said on Monday. The department is determining whether the documents point to evidence of corruption and other violations of U.S. law. “The U.S. […]

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Tax Court: Raising reasonable cause based on Sec. 482 exclusion rule waived attorney-client privilege

Tax Court:  Raising reasonable cause based on Sec. 482 exclusion rule waived attorney-client privilege

The Tax Court, in the case of Eaton Corporation and Subsidiaries v. Commissioner of Internal Revenue, Docket No. 5576-12, has determined that the particular reasonable cause argument that a domestic manufacturer made, concerning a substantial valuation misstatement with respect to the price of services performed for a controlled entity described in Code Sec. 482, waived […]

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Assertion of good-faith and state-of-mind defenses to penalty waived attorney-client privilege

Assertion of good-faith and state-of-mind defenses to penalty waived attorney-client privilege

In AD Investment 2000 Fund LLC, Community Media, Inc., a partner other than the tax matters partner, v. Commissioner, (2014) 142 TC No. 13, the Tax Court has concluded that the taxpayers’ assertion that they had reasonable cause and acted in good faith as a defense to penalties assessed by IRS put their legal knowledge […]

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Case Alert: Work product rule protected taxpayer’s documents, but attorney-expert rule did not

Case Alert: Work product rule protected taxpayer’s documents, but attorney-expert rule did not

In Veolia Environmental North America Operations, Inc., (DC DE 10/25/2013) 112 AFTR 2d ¶ 2013-5434, a district court has held that certain documents that a U.S. holding company refused to produce in response to an IRS summons were protected by the work product rule. However, it ruled that other of the taxpayer’s documents were not […]

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Court, defining limits of deliberative process privilege, orders IRS to disclose documents

Court, defining limits of deliberative process privilege, orders IRS to disclose documents

A  district court, in Desert Valley Painting & Drywall, Inc. v. U.S. (DC NV 10/5/2012), has ordered IRS to comply with the discovery requests of a taxpayer it claimed had misclassified its workers as independent contractors. The court determined that IRS couldn’t redact all factual information in, or entirely withhold, requested documents based on the […]

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Court compels disclosure of some purported tax shelter documents, protects others

Court compels disclosure of some purported tax shelter documents, protects others

In Santander Holdings USA, Inc. & Subsidiaries, v. United States of America, United States District Court (D. Massachusetts), Civil Action No. -09-11043- GAO, concerning documents pertaining to a purported tax shelter, a district court has found that the work product doctrine did not protect against disclosure of tax reserve work papers, and that the tax […]

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Case Alert: Lafler decision by U.S. Supreme Court – – what’s the best remedy?

A recent U.S. Supreme Court decision in Lafler v. Cooper, 132 S.Ct. 1376 (2012) has the criminal defense bar, prosecutors,  and bench buzzing.  In lay terms, the Supreme Court held that a criminal defendant’s lawyer provided “ineffective assistance of counsel” (a Constitutional violation), when that lawyer failed to properly advise the defendant of rejecting a […]

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FINCEN marches on – say goodbye to attorney-client confidentiality?

FINCEN marches on – say goodbye to attorney-client confidentiality?

A proposed federal rule aimed at reducing money laundering and terrorist financing could put the confidentiality of law firm clients at risk, according to the American Bar Association, in published comments.  Under the proposed rule, law firms that open new bank accounts on behalf of clients or deposit advanced legal fees in firm trust accounts […]

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Case Alert: Taxpayer’s Penalty Defense Caused Waiver of Work Product and Tax Practitioner Privileges

Case Alert:  Taxpayer’s Penalty Defense Caused Waiver of Work Product and Tax Practitioner Privileges

Editor’s Note:  My website discusses the differences between the attorney-client privilege and the engagement of an accountant separately, where there is no attorney-client privilege.   There are instances where we (the attorney and client) engage the services of an accountant or other other expert under the so-called Kovel privilege, named after a case.  We use that […]

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IRS Voluntary Disclosure – Option #2 – Participate “Somewhat” But Not Completely: Options for Taxpayers Contemplating the Program

IRS Voluntary Disclosure – Option #2 – Participate “Somewhat” But Not Completely:  Options for Taxpayers Contemplating the Program

I recently wrote about the background of the OVCI Program as it relates to unreported foreign income and the various options available to taxpayers, discussing Option #1 – Do Nothing.  There are basically three options: (1) Do Nothing: (2) Participate “Somewhat” But Not Completely; and (3) Participate Completely.  This article will discuss the second option, […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney