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Discharge of taxes

District Court – statute of limitations on collection extended by taxpayer bankruptcy, offer in compromise

District Court – statute of limitations on collection extended by taxpayer bankruptcy, offer in compromise

Fields, (DC NM 3/17/2016) 117 AFTR 2d ¶ 2016-528 A district court has approved IRS’s calculation of an extension of the statute of limitations (SOL) on collection based on the taxpayer’s bankruptcy and his submission of an offer in compromise. It also approved IRS’s foreclosing on its liens on the taxpayer’s property that arose from […]

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Supreme Court won’t review case denying discharge of tax debt on taxpayers’ late-filed return

Supreme Court won’t review case denying discharge of tax debt on taxpayers’ late-filed return

Mallo, (CA 10 12/29/2014) 114 AFTR 2d 2014-7022, cert denied 6/29/2015 The Supreme Court has declined to review a decision of the Court of Appeals for the Tenth Circuit that held that, except with respect to returns prepared with the assistance of IRS under Code Sec. 6020(a), debts with respect to late-filed tax returns are […]

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Penalties Dischargeable Where Tax Liability Accrued More Than 3 Years Before Bankruptcy Filing

Penalties Dischargeable Where Tax Liability Accrued More Than 3 Years Before Bankruptcy Filing

Wilson, (Bktcy Ct CA 2/25/2015) 115 AFTR 2d ¶ 2015-485 A Bankruptcy Court ruled that penalties for failure to file a tax return under Code Sec. 6651(a)(1) were dischargeable where the penalties were imposed upon tax liabilities that accrued more than three years before the filing of a bankruptcy petition, notwithstanding the fact that the […]

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Another circuit holds that tax debt on late-filed return rarely dischargeable in bankruptcy

Another circuit holds that tax debt on late-filed return rarely dischargeable in bankruptcy

The Court of Appeals for the First Circuit has held that, except with respect to returns prepared with the assistance of IRS under Code Sec. 6020(a), debts for unpaid taxes from late-filed tax returns are not dischargeable in bankruptcy. In so doing, it came to the same conclusion as the Fifth and Tenth Circuits.  Click here for In […]

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Lavish spending alone doesn’t prevent discharge of taxes in bankruptcy

Lavish spending alone doesn’t prevent discharge of taxes in bankruptcy

William M. Hawkins, III v. FTB, USA, IRS, (CA 9 9/15/2014) 114 AFTR 2d ¶2014-5247 The Court of Appeals for the Ninth Circuit has held that a district court improperly affirmed a bankruptcy court’s judgment that a taxpayer’s tax debts were excepted from discharge in a chapter 11 bankruptcy proceeding because his profligate spending showed […]

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Debtor’s tax liabilities not discharged in bankruptcy

Debtor’s tax liabilities not discharged in bankruptcy

In re Ollie-Barnes, (Bktcy Ct 11/06/2014) 114 AFTR 2d ¶ 2014-5413 A bankruptcy court has rejected a debtor’s claim that her federal tax liabilities were discharged in bankruptcy and noted that: 1) the fact that the tax debt was omitted from the bankruptcy trustee’s report of filed claims didn’t cause the claim to be disallowed […]

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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