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Claim for refund

U.S.-Swiss treaty prevented court from considering taxpayer’s refund claim

U.S.-Swiss treaty prevented court from considering taxpayer’s refund claim

Starr International Company, Inc., (DC Dist Col 2/2/2016) 117 AFTR 2d ¶ 2016-396 A district court held that the terms of the U.S.-Swiss tax treaty caused the court to “lack the power” to rule on a Swiss-domiciled corporation’s U.S income tax refund claim. The holding effectively reversed a previous holding of the court on this […]

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Refund claims by taxpayer were timely under informal claim doctrine

Refund claims by taxpayer were timely under informal claim doctrine

In Chief Counsel Advice (CCA) 201351019, Counsel has concluded that a taxpayer’s refund claims for certain years were timely. IRS knew or should have known that a refund claim was being made where the taxpayer made a refund request after IRS adjusted the taxpayer’s income, tax, and credits on the taxpayer’s returns, creating balances due. […]

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Lookback rule killed refund for taxpayer who didn’t qualify for limitations period tolling

Lookback rule killed refund for taxpayer who didn’t qualify for limitations period tolling

The Court of Federal Claims, in an unpublished opinion, in Olga E. Martinez v. United States (Ct. Fed. Cl. July 25, 2013), 112 AFTR 2d ¶ 2013-05119, dismissed a taxpayer’s refund suit. While her claim for refund was timely, the lookback rule prevented her from recovering the overpayment. She sought to escape the bar of the […]

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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