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Work Product Privilege

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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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 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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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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Associations
Member CA Bar Member Orange County Bar US Tax Court Attorney