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Partnerships

Tax Court declines to impose 40% penalty substantial underpayment penalty where underpayment wasn’t from misvaluation

Tax Court declines to impose 40% penalty substantial underpayment penalty where underpayment wasn’t from misvaluation

Editor’s Note:  a good case and victory for taxpayers in the case of Blak Investments v. Commissioner, T. C. Memo. 2012-273.  A complete copy of the Court’s opinion is here. The Honorable Juan F. Vasquez, Judge, U.S. Tax Court, issued the opinion, and Judge Vasquez  declined to impose the Code Sec. 6662(h) 40% gross valuation […]

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TIGTA Report: IRS No Change Audits – Favorable Trends in Partnership Audits But More Audits on the Way

TIGTA Report:  IRS No Change Audits – Favorable Trends in Partnership Audits But More Audits on the Way

Editor’s Note:  whenever a taxpayer, individual or otherwise, receives a “no change” in an audit-examination, it is always a good thing.  TIGTA analyzed no change audits in “partnership” returns, found some flaws in how the IRS goes about the process, and made some suggestions.  Future?  More audits regarding partnership returns (which flow through to individuals […]

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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