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Closing Agreement

Court of Appeals 9th Circuit – IRS breach of partnership closing agreement didn’t invalidate partner tax assessment

Court of Appeals 9th Circuit – IRS breach of partnership closing agreement didn’t invalidate partner tax assessment

Davis, (CA 9 1/25/2016) 117 AFTR 2d ¶ 2016-368 The Court of Appeals for the Ninth Circuit, reversing a district court decision, has upheld IRS’s assessment of taxes on a partner with respect to partnership items, even though IRS breached a clause in its closing agreement with the partnership. The Court also rejected the partner’s […]

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Tenth Circuit finds additional expenses weren’t deductible under closing agreement

Tenth Circuit finds additional expenses weren’t deductible under closing agreement

In U.S. v. ConocoPhillips Company, (CA 3/12/2014) 113 AFTR 2d ¶ 2014-596, the Court of Appeals for the Tenth Circuit, affirming a district court, has held that a taxpayer couldn’t expand the benefits of a closing agreement with IRS on the treatment of expenses incurred in developing an Alaskan pipeline. The closing agreement didn’t encompass […]

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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