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U.S. Supreme Court

U.S. Supreme Court wrestles with Puerto Rico restructuring case

U.S. Supreme Court wrestles with Puerto Rico restructuring case

Liberal justices on Tuesday signaled support for Puerto Rico as the U.S. Supreme Court considered whether to revive a law that could let the U.S. territory cut billions of dollars owed in debt at some public agencies, a key test in the island’s efforts to weather a huge fiscal crisis. It was unclear how the court will […]

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Court of Appeals – applying Supreme Court’s standards, Court finds no IRS bad faith and enforces summonses

Court of Appeals – applying Supreme Court’s standards, Court finds no IRS bad faith and enforces summonses

Clarke, (CA 11 3/15/2016) 117 AFTR 2d ¶ 2016-514 The Court of Appeals for the Eleventh Circuit, affirming a district court case heard on remand, has applied standards provided by the Supreme Court and held that taxpayers who received IRS summonses did not make a showing of facts that gave rise to a plausible inference […]

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Supreme Court won’t review case on IRS’s designation of hearing request as frivolous

Supreme Court won’t review case on IRS’s designation of hearing request as frivolous

Ryskamp, (CA DC 8/14/2015) 116 AFTR 2d 2015-5614, cert denied 1/11/2016 The Supreme Court has declined to review a decision of the Court of Appeals for the District of Columbia Circuit which held that Code Sec. 6330(g)’s prohibition of further review of frivolous requests for a collection due process (CDP) hearing does not preclude the […]

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Supreme Court won’t hear case finding foreign banks did not have capital interest in partnership

Supreme Court won’t hear case finding foreign banks did not have capital interest in partnership

TIFD III-E Inc. v. U.S., (CA 2 1/24/2012), 109 AFTR 2d 2012-632109 AFTR 2d 2012-632, cert denied 1/11/2016 The Supreme Court has declined to review the decision of the Court of Appeals for the Second Circuit, which, reversing the district court on remand for the second time, held that an interest overwhelmingly in the nature […]

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Supreme Court won’t review case involving IRS compelled production of foreign bank records

Supreme Court won’t review case involving IRS compelled production of foreign bank records

Chabot, (CA 3 7/17/2015) 116 AFTR 2d 2015-5270, cert denied 11/30/2015 The Supreme Court has declined to review a decision of the Court of Appeals for the Third Circuit which held that the “required records” exception to the Fifth Amendment privilege against self-incrimination applies to allow IRS to summon foreign bank account records. Note: Similar conclusions […]

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Effect of Supreme Court’s marriage equality ruling on employee benefit plans

Effect of Supreme Court’s marriage equality ruling on employee benefit plans

Notice 2015-86, 2015-52 IRB In a Notice, IRS has provided guidance on the application of the Supreme Court’s landmark marriage equality decision, Obergefell v. Hodges, to qualified retirement plans under Code Sec. 401(a) and to health and welfare plans, including cafeteria plans under Code Sec. 125. Background. Section 3 of the Defense of Marriage Act (DOMA) defined marriage […]

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Supreme Court won’t hear case finding couple & LLC were alter ego of delinquent corporation

Supreme Court won’t hear case finding couple & LLC were alter ego of delinquent corporation

Politte v. U.S., (CA 9 2/17/2015) 115 AFTR 2d 2015-874115 AFTR 2d 2015-874, cert denied 11/9/2015 The Supreme Court has refused to review a decision by the Court of Appeals for the Ninth Circuit that found that a married couple and their limited liability company were the alter ego of another family corporation that failed […]

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Supreme Court won’t review case involving state rules on donor disclosure

Supreme Court won’t review case involving state rules on donor disclosure

Center for Competitive Politics v. Harris, (CA 9 5/1/2015) 115 AFTR 2d 2015-1711, cert denied, 11/09/2015 The Supreme Court has declined to review a decision of the Court of Appeals for the Ninth Circuit that the Code’s rules limiting disclosure of the names of persons who contribute to tax-exempt organizations do not preclude a state […]

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Supreme Court won’t review denial of offset relief to misclassified employee

Supreme Court won’t review denial of offset relief to misclassified employee

Karagozian, (CA 2 3/2/2015) 115 AFTR 2d 2015-990, cert denied 10/19/2015 The Court of Appeals for the Second Circuit, affirming the Tax Court, has held that an employee who underpaid his 2008 income tax and overpaid his 2002-2008 FICA tax, as a result of his employer misclassifying him as self-employed, couldn’t use the equitable recoupment […]

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Proposed regs implement Supreme Court’s same-sex marriage decision

Proposed regs implement Supreme Court’s same-sex marriage decision

IRS has issued proposed regs that would provide that a marriage of two individuals, whether of the same sex or the opposite sex, will be recognized for federal tax purposes if that marriage is recognized by any State, possession, or territory of the U.S. The regs provide additional clarity on how the federal government will […]

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U.S. top court won’t hear satellite TV providers’ claim on state taxes

U.S. top court won’t hear satellite TV providers’ claim on state taxes

WASHINGTON (Reuters) – The U.S. Supreme Court on Monday rejected a bid by satellite television providers to challenge states taxes they say unlawfully treat them differently from cable TV companies. The nine justices turned away a joint challenge from DirecTV Inc, a subsidiary of AT&T Inc, and Dish Network Corp over taxes in Massachusetts and Tennessee. The […]

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Supreme Court won’t review case on partner’s ability to make partial election out of TEFRA

Supreme Court won’t review case on partner’s ability to make partial election out of TEFRA

JT USA LP; JTR-LLC; Tax Matters Partner, (CA 9 11/14/2014) 114 AFTR 2d 2014-6608, cert denied 10/5/2015 The Supreme Court has declined to review a decision of the Court of Appeals for the Ninth Circuit that held that unless a partner elects to have all of his or her partnership items treated as nonpartnership items, the partner […]

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Dodd-Frank Whistleblower Rules May Get A Supreme Court Showdown

Dodd-Frank Whistleblower Rules May Get A Supreme Court Showdown

The SEC has filed a series of friend-of-the-court briefs defending its rules that protect corporate whistleblowers from retaliation by their employers. The dispute, which revolves around competing interpretations of a Dodd-Frank Act provision, is likely headed for the Supreme Court, one attorney predicted. The SEC in August 2015 filed four appeals court briefs defending its […]

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DC Circuit applies Supreme Court’s holding on partnership item & outside basis

DC Circuit applies Supreme Court’s holding on partnership item & outside basis

Tigers Eye Trading, LLC, et al. v. Comm (CA DC 6/26/2015) 115 AFTR 2d ¶ 2015-862 Based on the Supreme Court’s recent holding in Woods, the Court of Appeals for the District of Columbia Circuit (DC Circuit) has affirmed the Tax Court’s decision that the Code Sec. 6662(h) gross valuation misstatement penalty applied to a partner in […]

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IRS Announcement – based on S. Ct Decision that severance pay is subject to FICA, IRS will deny refund claims

IRS Announcement – based on S. Ct Decision that severance pay is subject to FICA, IRS will deny refund claims

Ann. 2015-8, 2015-9 IRB In an Announcement, IRS has provided guidance on the application of the Supreme Court’s Quality Stores decision to claims for refund of employment taxes. In that decision the Supreme Court held that severance payments were wages subject to Federal Insurance Contributions Act (FICA) tax. IRS will disallow all claims for refund of FICA […]

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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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Top Obamacare official looks ahead after Supreme Court ruling

Top Obamacare official looks ahead after Supreme Court ruling

WASHINGTON (Reuters) – The U.S. official overseeing Obamacare said on Fridayshe has not seen any indication that states will back away from running their own health insurance marketplaces now that the Supreme Court has validated the federal insurance exchange. Sylvia Burwell, secretary of Health and Human Services, also said she expected enrollment in both the state […]

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Supreme Court Won’t Hear Case Denying Taxpayer Interest on Cash Bond Remittances

Supreme Court Won’t Hear Case Denying Taxpayer Interest on Cash Bond Remittances

Ford Motor Co. v. U.S., (CA 6, 2014) 114 AFTR 2d 2014-6173, cert denied 6/22/2015 The Supreme Court has refused to hear a case in which the Court of Appeals for the Sixth Circuit, affirming the district court, denied $445 million in overpayment interest on remittances made as cash bonds, until after the Ford Motor […]

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Supreme Court Holds that Same-Sex Marriage Equality is Constitutional Right

Supreme Court Holds that Same-Sex Marriage Equality is Constitutional Right

Obergefell v. Hodges (Supreme Court 6/26/2015). The Supreme Court, in a 5-4 decision delivered by Justice Kennedy, has held, in a case involving four state-wide bans on same-sex marriage, that the Fourteenth Amendment requires a State to license a marriage between two people of the same sex. And, since same-sex couples may now exercise the […]

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Supreme Court holds that Constitution compels nationwide right to same-sex marriage

Supreme Court holds that Constitution compels nationwide right to same-sex marriage

The Supreme Court, in a 5-4 decision delivered by Justice Kennedy, has struck down four state-wide bans on same-sex marriage, holding that the Fourteenth Amendment requires all States to license a marriage between two people of the same sex. And, since same-sex couples may now exercise the fundamental right to marry in all States, there […]

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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