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At Risk

IRS Reviews Consequences of Foreclosures Involving Nonrecourse or Recourse Debt

IRS Reviews Consequences of Foreclosures Involving Nonrecourse or Recourse Debt

IRS recently issued an Audit Techniques Guide (ATG) on foreclosure, a complex topic that has swamped practitioners and IRS alike in recent years due to the extended fallout from the subprime mortgage crisis. One of the many topics of interest is the foreclosure of properties with nonrecourse or recourse mortgages. This article reviews the ATG’s […]

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District Court Case: Owner of LLC who co-guaranteed loan was 50% at risk & not subject to PAL limits

District Court Case: Owner of LLC who co-guaranteed loan was 50% at risk & not subject to PAL limits

Moreno, et al, (DC LA 5/19/2014) 113 AFTR 2d ¶ 2014-839. A district court has determined on summary judgment that a taxpayer was at risk with respect to the aircraft leasing activity of his wholly owned limited liability company (LLC), but was only at risk with respect to 50% of a loan taken out by […]

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Cruise prices sink to all-time lows

Cruise prices sink to all-time lows

As reported in the news of the WS Journal, Cruise prices sink to all-time lows – It may now be cheaper to book a cruise than stay in a Motel 6. Deals on cruises right now are the best they have been in years, insiders say. Louis Ramirez, senior editor at deal aggregator DealNews, says […]

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Court of Appeals denies pass-thru losses, deductions, and amortization of cell phone businesses

Court of Appeals denies pass-thru losses, deductions, and amortization of cell phone businesses

The Court of Appeals for the Sixth Circuit, in Broz v. Comm., (CA 6 8/23/2013) 112 AFTR 2d ¶ 2013-5231, affirming the Tax Court, has found that a cellular service entrepreneur couldn’t deduct pass-through losses from his S corporation because he lacked the required basis in his S corporation. The Court also denied the business […]

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Retained rights don’t prevent guarantor from being at-risk but co-guarantors do, per IRS Chief Counsel Advice 2013-08028

Retained rights don’t prevent guarantor from being at-risk but co-guarantors do, per IRS Chief Counsel Advice 2013-08028

In Chief Counsel Advice (CCA) 2013-08028, IRS has determined that the guarantor of debt of a limited liability company (LLC) may be “at risk” under Code Sec. 465 with respect to the guaranteed debt, even if he doesn’t waive his rights of subrogation and reimbursement from the LLC. However, the CCA went on to conclude […]

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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