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Capitalization

Fifth Circuit finds custom homebuilder subject to UNICAP rules

Fifth Circuit finds custom homebuilder subject to UNICAP rules

Frontier Custom Builders, Incorporated v. Comm., (CA 5, 9/16/2015) 116 AFTR 2d ¶ 2015-5251 The Court of Appeals for the Fifth Circuit, affirming the Tax Court, has held that a custom homebuilder was subject to the Code Sec. 263A uniform capitalization (UNICAP) rules in the same way that a speculative homebuilder was. Accordingly, the Court […]

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Court of Appeals 2nd Circuit: taxpayer didn’t qualify for small reseller’s exception to UNICAP rules

Court of Appeals 2nd Circuit: taxpayer didn’t qualify for small reseller’s exception to UNICAP rules

City Line Candy & Tobacco Corp. v. Comm. (CA 2, 9/30/2015) 116 AFTR 2d ¶ 2015-5293 The Court of Appeals for the Second Circuit, affirming the Tax Court, has concluded that a reseller and wholesaler of cigarettes couldn’t rely on the small reseller’s exception to the Code Sec. 263A uniform capitalization (UNICAP) rules because it […]

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How capitalization regs’ safe harbor boosts year-end deductions despite Sec. 179 cutback

How capitalization regs’ safe harbor boosts year-end deductions despite Sec. 179 cutback

Businesses that have benefitted from the generous $500,000 Code Sec. 179 expensing limit for tangible personal property (and certain software) for the past few years may be in for an unwelcome surprise this year. Unless Congress acts to retroactively restore generous expensing, starting with qualified property placed in service in tax years beginning after 2014, […]

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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