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Civil Assessment Period

IRS explains refund limit where multiple assessment extensions have been filed

IRS explains refund limit where multiple assessment extensions have been filed

In Chief Counsel Advice (CCA) 201349014, IRS explains how the Code Sec. 6511(c)(2) limitation on refunds is applied where multiple extensions of time to assess tax have been agreed to by IRS and the taxpayer. Background. In general, a refund or credit claimed or allowed before execution of a waiver extending the assessment period is […]

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Tax shelter promoter’s fraudulent intent insufficient to keep limitations period open

Tax shelter promoter’s fraudulent intent insufficient to keep limitations period open

The Court of Federal Claims in BASR Partnership v. U.S., (Ct Fed Cl 09/30/2013) 112 AFTR 2d ¶2013-5343, has determined that a final partnership administrative adjustment (FPAA) issued by IRS to a family limited partnership, which was used as part of a tax shelter transaction, was untimely, and that the partnership was entitled to a […]

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New guidance clarifies IRS procedures in cases involving criminal restitution & civil liability

New guidance clarifies IRS procedures in cases involving criminal restitution & civil liability

In a Chief Counsel Notice (CCN) 2013-012, IRS’s Office of Chief Counsel has provided guidance to its attorneys on how to properly review statutory deficiency notices issued pursuant to a civil examination for tax periods also covered by a restitution order in a criminal tax case. The CCN also clarifies previously-issued guidance on the treatment […]

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Tax assessment period for company was tolled by embezzling accountant’s fraud

Tax assessment period for company was tolled by embezzling accountant’s fraud

In City Wide Transit Inc. v. Commissioner, (Court of Appeals 2nd Cir.  March 1, 2013), the Court of Appeals for the Second Circuit, reversing the Tax Court, has concluded that IRS could make an employment tax assessment after Code Sec. 6501(a)’s three-year statute of limitations expired because the company’s returns at issue had been fraudulently […]

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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