Contact Paul +

Time limit is exhausted. Please reload CAPTCHA.

Chief Counsel Memo

IRS instructs its attorneys on proper venue for appellate review of CDP cases

IRS instructs its attorneys on proper venue for appellate review of CDP cases

In a Chief Counsel Notice, IRS has provided guidance to its attorneys on the effect of the DC Circuit’s Byers decision on venue for appeals from collection due process (CDP) and other non-deficiency decisions of the Tax Court. In Byers, the DC Circuit, contrary to the longstanding practice of taxpayers and IRS, held that under […]

Read the full article →

IRS clarifies effect, on adoption credit, of foreign child not being “re-adopted”

IRS clarifies effect, on adoption credit, of foreign child not being “re-adopted”

Chief Counsel Advice 201509037 In an e-mail Chief Counsel Advice (CCA), IRS has clarified the effect, on the adoption credit, of certain foreign-born children not being “re-adopted” under state law. Background. An individual can claim a tax credit for qualified adoption expenses (QAE) which are reasonable and necessary adoption fees, court costs, attorney fees, and […]

Read the full article →

IRS Disagrees With Tax Court Ruling On Employment Status Jurisdiction; Issues Guidance

IRS Disagrees With Tax Court Ruling On Employment Status Jurisdiction; Issues Guidance

IRS’s Office of Chief Counsel has issued guidance on when to issue a Notice of Determination of Worker Classification (NDWC) under Code Sec. 7436 and how to handle docketed Tax Court cases when employment taxes are involved. This guidance was issued in light of a Tax Court opinion, SECC Corporation, (2014) 142 TC No. 12, […]

Read the full article →

Drug maker seeking FDA approval must capitalize patent infringement defense costs

Drug maker seeking FDA approval must capitalize patent infringement defense costs

Legal Advice Issued by Associate Chief Counsel 2014-006 In Legal Advice Issued by Associate Chief Counsel, IRS has concluded that where a drug manufacturer seeks Food and Drug Administration (FDA) approval to sell a generic equivalent of a drug for which a patent exists but which the manufacturer claims is invalid, unenforceable or will not […]

Read the full article →

IRS provides litigation guidance on refundable credits and the accuracy-related penalty

IRS provides litigation guidance on refundable credits and the accuracy-related penalty

Chief Counsel Notice 2014-007 Click here for Chief Counsel Notice 2014-007. In a Chief Counsel Notice (CCN), IRS has provided guidance to its attorneys litigating Tax Court cases involving the accuracy-related or fraud penalty determined with respect to disallowed refundable credits in light of the Tax Court’s recent decision in Rand. Background. Code Sec. 6662(a) […]

Read the full article →

What is the value and utility of regs, rulings, and other IRS documents? – Part II

What is the value and utility of regs, rulings, and other IRS documents? – Part II

IRS issues a wide variety of documents every week, some of which are written for public release and others of which are for IRS’s internal use but are ultimately released under the Freedom of Information Act. Whether written for internal or public use, IRS administrative pronouncements vary in precedential value and utility. This 2-part Practice […]

Read the full article →

Where loan forgiveness depends on job creation, income is deferred under all-events test, per Chief Counsel Memo 2012-2014

Where loan forgiveness depends on job creation, income is deferred under all-events test, per Chief Counsel Memo 2012-2014

A Chief Counsel Memo (CCM) 2012-2014, concludes that an advance from a state to a company that was partially or completely cancellable depending on how many jobs the company was a bona fide loan rather than a prepayment for services to be rendered (i.e., job creation). The company could defer reporting income from any loan […]

Read the full article →
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.

Read More

Connect With Paul on Social Media

Practice Areas & Information

Certifications &
Associations
Member CA Bar Member Orange County Bar US Tax Court Attorney