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U.S. Bankruptcy Court

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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Supreme Court won’t decide effect of bankruptcy petition on appeal of Tax Court case

Supreme Court won’t decide effect of bankruptcy petition on appeal of Tax Court case

We previously blogged on this case. Now, the Supreme Court, in Schoppe v. Commissioner, (CA 10 03/28/2013) 111 AFTR 2d 2013-1398, cert denied 10/07/2013, has declined to review a decision of the Tenth Circuit that a taxpayer’s filing of a bankruptcy petition doesn’t operate as a stay of his appeal of an adverse Tax Court […]

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Hedge funds score big win bankrolling tax refund case

Hedge funds score big win bankrolling tax refund case

As reported in the news, a group of hedge funds looks set to win an eyewatering return after bankrolling the winning party in a court fight over a $373.8 million tax refund in the bankruptcy of Downey Financial Corp. U.S. Bankruptcy Judge Christopher Sontchi ruled that the disputed tax return belonged to Downey. The Federal […]

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Justice Department Issues New Guidelines for Payment of Attorneys’ Fees, Expenses, in Large Chapter 11 Bankruptcy Cases

Justice Department Issues New Guidelines for Payment of Attorneys’ Fees, Expenses, in Large Chapter 11 Bankruptcy Cases

According to the recent DOJ Press Release, the Department of Justice today (June 11) announced new guidelines for the payment of attorneys’ fees and expenses in large chapter 11 bankruptcy cases in order to enhance disclosure and transparency in the compensation process and to help ensure that attorneys’ fees and expenses are based on market […]

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Orange County bankruptcy filings drop nearly 22%

Orange County bankruptcy filings drop nearly 22%

Seems as if there is some good news as we move into 2013:  In the news of the OC Register, it was reported that Orange County bankruptcies had dropped nearly 22%.  Sign of the times? November bankruptcy filings in Orange County followed the recent pattern of year-over-year decline, reaching the lowest monthly total since February […]

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Update on Solyndra bankruptcy: IRS appeals denial of its objection to plan saying it allows the company to avoid paying taxes

Update on Solyndra bankruptcy:  IRS appeals denial of its objection to plan saying it allows the company to avoid paying taxes

Editor’s Note:  Update to the article/blog posted today entitled “IRS objects to Chapter 11 bankruptcy plan based on alleged tax avoidance purpose,” as the IRS filed its Notice of Appeal.   The basic argument is that a company with no assets or any business activity is nothing more than a shell and thus should not be […]

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IRS objects to Chapter 11 bankruptcy plan based on alleged tax avoidance purpose

IRS objects to Chapter 11 bankruptcy plan based on alleged tax avoidance purpose

Editor’s Note:  Solyndra, LLC is an interesting case as IRS lost its objection to a plan of reorganization based on the fact that the primary purpose of the plan was “tax avoidance” despite some rather compelling facts.  In brief, IRS has filed an objection to the proposed joint Chapter 11 bankruptcy plan of Solyndra, a […]

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Orange County Bankruptcies Drop 15% in April

Orange County Bankruptcies Drop 15% in April

As reported by Jan Norman, OC Register, some more good news, . . . In April 1,385 individuals and businesses filed for bankruptcy protection, 15.5% fewer than a year ago, according to the latest data from the U.S. Bankruptcy Court Central District of California. The above source is from the U.S. Bankruptcy Court Central District […]

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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