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all events test

Supreme Court won’t review decision that company’s projected dividends fail all events test

Supreme Court won’t review decision that company’s projected dividends fail all events test

In New York Life Insurance Co. v. U.S., (CA 2 08/01/2013) 112 AFTR 2d 2013-5555, cert denied 4/28/2014, the Supreme Court has declined to review a Second Circuit decision that upheld the dismissal of a life insurance company’s refund complaint on the basis that the company can’t claim Code Sec. 808(c) deductions in the year […]

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Tax Court rejects corporation’s accelerated deductions for failure to satisfy all events test

Tax Court rejects corporation’s accelerated deductions for failure to satisfy all events test

In Veco Corporation v. Commissioner (2013) 141 T.C. No. 14, the Tax Court has upheld IRS’s determination that an accrual method taxpayer wasn’t entitled to the majority of the accelerated deductions that it claimed resulting from its proposed accounting method change. The Court found that the taxpayer failed to prove that the all events test […]

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Conditions placed on bonuses prevented them from being deductible before payment

Conditions placed on bonuses prevented them from being deductible before payment

In Legal Advice Issued by Field Attorneys (LAFA), 2013-4301F, IRS has concluded that where an employer taxpayer retained the unilateral right to modify or eliminate employee bonuses at any time prior to payment, the taxpayer’s liability arising from bonus compensation was only taken into account under the all events test for accruing expenses in the […]

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Court of Appeals Second Circuit affirms: insurance company’s projected dividend payments fail “all events” test

Court of Appeals Second Circuit affirms: insurance company’s projected dividend payments fail “all events” test

 The Court of Appeals for the Second Circuit in New York Life Insurance Co. v. United States (2nd Cir., August 1, 2013) 112 AFTR 2d ¶ 2013-5152, has affirmed the district court’s dismissal of a life insurance company’s refund complaint, finding that the company can’t claim Code Sec. 808(c) deductions in the year that dividends […]

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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