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Casualty Loss

Disaster victims in Louisiana qualify for tax relief

Disaster victims in Louisiana qualify for tax relief

IRS has announced on its website that victims of the severe storms and flooding in parts of Louisiana that are designated as federal disaster areas qualifying for individual assistance have more time to make tax payments and file returns. Certain other time-sensitive acts also are postponed. This article summarizes the relief that’s available and includes […]

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Fifth Circuit holds residential land developer couldn’t use completed contract method

Fifth Circuit holds residential land developer couldn’t use completed contract method

Howard Hughes Company, L.L.C. v. Comm. (CA 5 10/27/2015) 116 AFTR 2d ¶ 2015-5368 The Court of Appeals for the Fifth Circuit, affirming the Tax Court, has concluded that none of the taxpayers’ contracts were home construction contracts under Code Sec. 460(e), so they couldn’t account for them using the completed contract accounting method. Background. A […]

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Car rental company gets no casualty loss for customer damage to cars

Car rental company gets no casualty loss for customer damage to cars

Chief Counsel Advice 201529008 In Chief Counsel Advice (CCA), IRS has held that, where customers of a car rental company damage the company’s cars, and the customers have purchased a damage waiver, the company does not have a casualty loss. Background. Code Sec. 162(a) allows a deduction for all the ordinary and necessary expenses paid or […]

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No profit motive in partnerships organized to make charitable contributions

No profit motive in partnerships organized to make charitable contributions

McElroy, TC Memo 2014-163 The Tax Court has concluded that a taxpayer lacked the requisite profit motive under Code Sec. 165(a) and Code Sec. 165(c)(2) to deduct the losses he claimed with regard to his investment in three partnerships that were organized with the goal of providing investors in the partnerships with charitable contribution deductions. […]

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The Rules on Deducting Capital Losses -You Can’t Always Use Losses to Offset Capital Gains

The Rules on Deducting Capital Losses  -You Can’t Always Use Losses to Offset Capital Gains

The Rules on Deducting Capital Losses -You Can’t Always Use Losses to Offset Capital Gains, as reported in the WS Journal. Q: Suppose you are thinking of selling your primary residence with a long-term loss in value and at the same time selling some stocks with long-term capital gain. A perfect offset, yes? — W.D.A., […]

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Lack of permits not fatal to casualty loss for buildings destroyed by forest fire

Lack of permits not fatal to casualty loss for buildings destroyed by forest fire

In Chief Counsel Advice (CCA), 201346009, IRS concluded that there were not sufficient public policy grounds to deny a casualty loss deduction for an uninsured residence and related building that were constructed without the required permits and were later totally destroyed by a forest fire. Facts. Taxpayers purchased a parcel of mountain property jointly with […]

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IRS Special Edition Tax Tip 2013-14 – Don’t Fall for Charity Scams Following Disasters

IRS Special Edition Tax Tip 2013-14 – Don’t Fall for Charity Scams Following Disasters

IRS Special Edition Tax Tip 2013-14 – Don’t Fall for Charity Scams Following Disasters. The IRS warns consumers not to fall for bogus charity scams. They often occur in the wake of major disasters like the recent tornadoes in the Midwest or the typhoon in the Philippines. Thieves play on the goodwill of people who […]

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Storm-season primer on casualty loss deductions for personal-use property

Storm-season primer on casualty loss deductions for personal-use property

Taxpayers who experience certain types of major personal casualties may be able to recoup some of their losses through tax savings.With storm season upon us, it is worth familiarizing yourself with the casualty loss rules and requirements in the event that disaster strikes.This article explains the mechanics of casualty loss deductions, as well as how […]

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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