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Cancellation of Indebtedness

IRS may be able to adjust repurchased debt COD income deferred from a closed year

IRS may be able to adjust repurchased debt COD income deferred from a closed year

Chief Counsel Advice 201604017 In Chief Counsel Advice (CCA), IRS has concluded that it may be able to adjust the amount of cancellation of debt (COD) income that a taxpayer has elected to defer under Code Sec. 108(i) even if the tax year of the election is closed. It instructed its attorneys who encounter such […]

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Tax relief provided to certain students whose education loans were discharged

Tax relief provided to certain students whose education loans were discharged

Rev Proc 2015-57, 2015-51 Note:  We recently blogged on this topic. In a Revenue Procedure, IRS has provided that taxpayers who took out Federal student loans to finance attendance at certain schools, and whose loans were discharged under the Department of Education’s Defense to Repayment or Closed School discharge processes, will not have to recognize […]

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Tax Court – Turning debt over to collection agency didn’t overcome presumption of uncollectibility

Tax Court – Turning debt over to collection agency didn’t overcome presumption of uncollectibility

Clark, TC Memo 2015-175 The Tax Court has held that the mere fact that a financial institution creditor turned over a debt to a collection agency after the expiration of the non-payment period described in Reg. § 1.6050P-1(b)(2)(i)(H) was insufficient to overcome a rebuttable presumption in the regs that the debt had already been discharged. […]

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Tax Court – Consolidated group’s NOL, not individual members’ NOLs, reduced by excluded COD income

Tax Court – Consolidated group’s NOL, not individual members’ NOLs, reduced by excluded COD income

Marvel Entertainment, LLC, (07/21/2015) 145 TC No. 21 The Tax Court has held that, where members of a consolidated group have cancellation of debt (COD) income that is excluded under Code Sec. 108, and the attribute that is reduced as a result of that exclusion is net operating loss (NOL), it is the consolidated group’s […]

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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