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Action on Decision

IRS disagrees with decision that compensation for preparer malpractice wasn’t taxable

IRS disagrees with decision that compensation for preparer malpractice wasn’t taxable

AOD 2016-001,04/18/2016 In an Action on Decision (AOD), IRS has announced its nonacquiesence with a Tax Court decision that held that a portion of the amount a taxpayer received from an accounting firm that advised it to enter into an abusive tax shelter — as settlement in the taxpayer’s suit for the firm’s fees, losses […]

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IRS disagrees with decision allowing non-farmer to exclude CRP payments from SE income

IRS disagrees with decision allowing non-farmer to exclude CRP payments from SE income

AOD 2015-02,09/23/2015 In an Action on Decision (AOD), IRS has announced its nonacquiesence with an Eighth Circuit decision that held that Conservation Reserve Program (CRP) payments from the federal government to a non-farmer to implement a conservation plan on CRP properties were excluded from net earnings from self-employment as rentals from real estate under Code […]

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IRS disagrees with partner exclusion of partnership’s debt cancellation income

IRS disagrees with partner exclusion of partnership’s debt cancellation income

AOD 2015-001, 02/09/2015   In an Action on Decision (AOD), IRS has announced its nonacquiesence with four Tax Court cases each of which held that a partner, who guaranteed the debt of a partnership and was not in bankruptcy in his individual capacity, may exclude from gross income under Code Sec. 108(a), partnership debt cancelled […]

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IRS won’t acquiesce in designation of specific employee for employment tax payment

IRS won’t acquiesce in designation of specific employee for employment tax payment

AOD 2014-01, 09/15/2014 In an Action on Decision (AOD), IRS has indicated that it will not follow (acquiesce in) the Tax Court’s holding in Dixon, (2013) 141 TC 173, which held that an employer can designate payments of its employment taxes to the income taxes of specific employees, because it effectively overrides the statutory limitations […]

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What is the value and utility of regs, rulings, and other IRS documents? – Part II

What is the value and utility of regs, rulings, and other IRS documents? – Part II

IRS issues a wide variety of documents every week, some of which are written for public release and others of which are for IRS’s internal use but are ultimately released under the Freedom of Information Act. Whether written for internal or public use, IRS administrative pronouncements vary in precedential value and utility. This 2-part Practice […]

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IRS rejects uncertain state of the law as ground by itself for reasonable cause defense to penalty

IRS rejects uncertain state of the law as ground by itself for reasonable cause defense to penalty

In an Action on Decision, AOD 2012-05,02/11/2013, IRS, nonacquiesing in the decision in Patel v Commissioner, (2012) 138 TC No. 23, has concluded that a finding that the state of the law was uncertain at the time a taxpayer’s return was filed, without a further finding that the taxpayer made a reasonable inquiry as to […]

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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