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Bad Debt Deduction

IRS: bank bad debt writeoffs that meet regulatory, etc. rules meet tax writeoff rules

IRS: bank bad debt writeoffs that meet regulatory, etc. rules meet tax writeoff rules

IRS’s Large Business and International (LB&I) division has issued a directive which provides that its auditors are to accept charge-off amounts reported by banks and bank subsidiaries for generally accepted accounting principles (GAAP) or regulatory purposes as sufficient evidence of worthlessness. The directive does not apply to small banks that use the reserve method of […]

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SEC Freezes Assets of Missing Georgia-Based Investment Adviser

SEC Freezes Assets of Missing Georgia-Based Investment Adviser

Editor’s Note:  often in the cases we handle there are cross investigations with different federal and/or state agencies.  One example, is the Securities and Exchange Commission.  This news event caught my eye and it is fairly typical of what happens – – Ponzi scheme, investor losses, IRS investigation, no deduction or limited deductions [read:  Bernie […]

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Tax Court holds taxpayer did not incur “cancellation of debt” income” – Hooray, one for the good guys, . . .

Tax Court holds taxpayer did not incur “cancellation of debt” income” – Hooray, one for the good guys, . . .

Editor’s Note:  In this day and time of mounting debt, a good case for taxpayers was recently decided in which the Tax Court held that the taxpayers did not incur “cancellation of debt” income.  The case is from the Tax Court but is a Summary Opinion and may not be relied upon as precedent. The […]

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California Personal Income Tax – Bad debt deduction denied

California Personal Income Tax – Bad debt deduction denied

Editor’s Note: this is a good case for illustrating the oft stated principle that until a bad debt becomes worthless, it is not deductible. In a case not to be cited as precedent, the California State Board of Equalization (SBE) in Consolidated Appeal of Zamora Sod Farm, et al., SBE, Case Nos. 487206; 487208; 487209, […]

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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