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Collection

District Court – statute of limitations on collection extended by taxpayer bankruptcy, offer in compromise

District Court – statute of limitations on collection extended by taxpayer bankruptcy, offer in compromise

Fields, (DC NM 3/17/2016) 117 AFTR 2d ¶ 2016-528 A district court has approved IRS’s calculation of an extension of the statute of limitations (SOL) on collection based on the taxpayer’s bankruptcy and his submission of an offer in compromise. It also approved IRS’s foreclosing on its liens on the taxpayer’s property that arose from […]

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Court of Appeals approves sale of home to satisfy one spouse’s tax liability

Court of Appeals approves sale of home to satisfy one spouse’s tax liability

U.S. v. Davis, (CA 6 3/9/2016) 117 AFTR 2d ¶ 2016-499 The Court of Appeals for the Sixth Circuit, affirming a district court, has concluded that IRS could enforce its tax lien and sell the primary residence owned by the taxpayer and her tax-delinquent husband. The Court rejected the argument of the taxpayer, who did […]

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Revised Offer in Compromise Booklet and Application – Updated Allowable Living Expense Standards for 2016

Revised Offer in  Compromise Booklet and Application – Updated Allowable Living Expense Standards for 2016

Revised Offer in Compromise Booklet and Application Coming The 2016 revision to Offer in Compromise Booklet Form 656-B will be available for download on Monday March 28. The booklet contains necessary forms and instructions for submitting an Offer in Compromise. Use of earlier versions may result in a delay in the processing of Offer applications. Information […]

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Washington Alert – IRS appeals loss in Altera Corp.; IRS Whistleblower Awards on the rise; Reminder for Health Coverage Tax Credit; IRS’s Collection function was responsible for generating $35.7 billion in revenue during FY 2015

Washington Alert – IRS appeals loss in Altera Corp.; IRS Whistleblower Awards on the rise; Reminder for Health Coverage Tax Credit; IRS’s Collection function was responsible for generating $35.7 billion in revenue during FY 2015

IRS has appealed its loss in Altera Corp, (2015) 145 TC No. 3, to the Ninth Circuit. In the earlier case, the Tax Court invalidated the requirement in 2003 final regs that related parties entering into qualified cost sharing arrangements are required to share stock-based compensation costs under Code Sec. 482. The Tax Court held […]

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Joint Explanatory Statement of the Committee of Conference – Tax provisions in the “Fixing America’s Surface Transportation (FAST) Act”

Joint Explanatory Statement of the Committee of Conference – Tax provisions in the “Fixing America’s Surface Transportation (FAST) Act”

Joint Explanatory Statement of the Committee of Conference On December 3, one day before the expiration of the previously-passed temporary funding measure, both chambers of Congress passed H.R.22, the “Fixing America’s Surface Transportation (FAST) Act”. The bill was sent to President Obama for his expected signature. In addition to authorizing federal surface transportation programs through […]

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No levy to be imposed on Social Security disability insurance payments

No levy to be imposed on Social Security disability insurance payments

In a memo to its Collection staff, IRS’s Small Business/Self-Employed (SB/SE) Division has stated that it will not levy on Social Security disability insurance payments that are payable after Oct. 3, 2015. Click here for IRS’s Small Business/Self-Employed Division memo “Federal Payment Levy Program – Exclude Disability Insurance Payments” (Oct. 7, 2015). Background. Code Sec. 6331(a) […]

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IRS correspondence was “notice and demand” that ended stay of collection statute of limitations

IRS correspondence was “notice and demand” that ended stay of collection statute of limitations

Godley, Jr., (DC NC 9/29/2015) 116 AFTR 2d ¶ 2015-5295 A district court has held that: a) the suspension of the 10-year statute of limitations (SOL) on tax collection, that applies when an estate’s Code Sec. 6166 (deferred payment of estate tax) election is in place, is lifted when the estate fails to timely make […]

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Washington Alert – GAO report on IRS Collection; Webinar on Independent Contractors; US and Slovak Republic sign IGA; Tax Policy paper on the Cadillac tax

Washington Alert – GAO report on IRS Collection; Webinar on Independent Contractors; US and Slovak Republic sign IGA; Tax Policy paper on the Cadillac tax

A recent report by the Government Accountability Office (GAO) focused on IRS’s collection process and found it heavily relies on the use of automation to categorize and route unpaid tax or unfiled tax return cases for potential selection. (GAO-15-647) The agency’s automated Inventory Delivery System (IDS) is used to categorize and route cases based on […]

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Washington Alert – CMS concerned of loss of ACA’s premium tax credit; IRS Collection being proactive on payroll taxes; JCT Report onMacroeconomic Effects of the ‘Tax Relief Extension Act of 2015

Washington Alert – CMS concerned of loss of ACA’s premium tax credit; IRS Collection being proactive on payroll taxes; JCT Report onMacroeconomic Effects of the ‘Tax Relief Extension Act of 2015

Federal officials, including those at the Centers for Medicare and Medicaid Services (CMS), are continuing to voice concerns regarding the possibility that up to an estimated 1.8 million households could lose their eligibility to receive the Affordable Care Act’s premium tax credit in 2016. Based on Treasury Department data, these households have been receiving the […]

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IRS Addresses Professional Employer Organization Failure to Pay Taxes on Pre-4/1/14 Wages

IRS Addresses Professional Employer Organization Failure to Pay Taxes on Pre-4/1/14 Wages

IRS’s Small Business/Self-Employed Division (SB/SE) has issued guidance to its Collection department employees regarding collecting taxes that were due to be paid by a professional employee organization (PEO) with respect to wages paid before Apr. 1, 2014, but were not paid by the PEO. Background. An employer may choose to enter into an agreement with a […]

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Washington Alert – IRS loses Collection staff per TIGTA; JCT Report onthe Financing of Surface Transportation Infrastructure; District Court status on FOIA case and Lois Lerner

Washington Alert – IRS loses Collection staff per TIGTA; JCT Report onthe Financing of Surface Transportation Infrastructure; District Court status on FOIA case and Lois Lerner

Due to ongoing budget cuts, since fiscal year 2010, IRS has lost 21% of its Automated Collection Service (ACS) contact representatives and 28% of its Field Collection revenue officers, according to a recent Treasury Inspector General for Tax Administration (TIGTA) audit. (Audit Report No. 2015-30-035) The audit stressed the importance of collection employees since their […]

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Washington Alert – TIGTA Report on IRS and ACA; Taxpayer ‘fundamental rights’; CBO Report on SSA benefits

Washington Alert – TIGTA Report on IRS and ACA; Taxpayer ‘fundamental rights’; CBO Report on SSA benefits

During the second half of fiscal year 2014, the Treasury Inspector General for Tax Administration (TIGTA) completed 75 audits and 1,636 investigations, according to a report the agency recently released. (Semiannual Report to Congress – April 1, 2014-Sept. 30, 2014) TIGTA’s combined audit and investigation efforts “recovered, protected and identified monetary benefits totaling $16.6 billion,” […]

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Request for installment agreement doesn’t preclude issuance of levy intent notice

Request for installment agreement doesn’t preclude issuance of levy intent notice

Eichler, (2014) 143 TC No. 2 The Tax Court has held the Code provision that prohibits IRS from making a levy while an offer for an installment agreement is pending does not prohibit IRS from issuing a notice of intent to levy while such an offer is pending. It also held that IRS’s decision not […]

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Collection period not extended by protective election that was never finalized

Collection period not extended by protective election that was never finalized

In Baileys v. United States, (DC CA 3/25/2014) 113 AFTR 2d ¶ 2014-751, a district court has ruled that the fact that an estate made a protective election under Reg. § 20.6166-1(d) to pay its estate tax in installments didn’t extend the ten-year period for collection of the tax because the election was never finalized. […]

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IRS Direct Pay Now Available on IRS.gov

IRS Direct Pay Now Available on IRS.gov

IRS announced that taxpayers can now pay their tax bills directly from their checking or savings accounts using IRS Direct Pay. It’s secure, free of charge and available on IRS.gov.  It has been around for many years. It takes just 5 easy steps to make a payment:

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TIGTA: Recalculations of the Collection Staute Expiration Date Were Not Always Accurate

TIGTA:  Recalculations of the Collection Staute Expiration Date Were Not Always Accurate

TIGTA: Recalculations of the Collection Staute Expiration Date Were Not Always Accurate – Highlights Highlights of Report Number: 2013-30-098 to the Internal Revenue Service Commissioners for the Small Business/Self-Employed Division and the Wage and Investment Division. IMPACT ON TAXPAYERS The Collection Statute Expiration Date (CSED) ends the Government’s right to pursue collection of a tax […]

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TIGTA: Fiscal Year 2013 Review of Compliance With Legal Guidelines When Conducting Seizures Of Taxpayers’ Property

TIGTA: Fiscal Year 2013 Review of Compliance With Legal Guidelines When Conducting Seizures Of Taxpayers’ Property

Taking a taxpayer’s property for unpaid tax is commonly referred to as a “seizure.”  To ensure that taxpayers’ rights are protected in this process, the IRS Restructuring and Reform Act of 1998 amended the seizure provisions in Internal Revenue Code (I.R.C.) Sections (§§) 6330 through 6344.  The IRS did not always comply with certain statutory […]

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National Taxpayer Advocate Identifies Priority Issues for Upcoming Year; Reports on Exempt Organization Review Concerns

National Taxpayer Advocate Identifies Priority Issues for Upcoming Year; Reports on Exempt Organization Review Concerns

IR-2013-63, National Taxpayer Advocate Nina E. Olson today (June 26) released her statutorily mandated mid-year report to Congress that identifies the priority issues the Taxpayer Advocate Service (TAS) will address during the upcoming fiscal year. The report expresses particular concern about the impact of budget cuts on the IRS’s ability to meet taxpayer needs, the […]

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IRS claim against Tyco may force former units to contribute to tax bill

IRS claim against Tyco may force former units to contribute to tax bill

As reported in Reuters, Security services provider ADT Corp said it may have to contribute to a tax bill faced by former parent Tyco International Ltd if the total amount assessed by the IRS exceeded $1.85 billion. Tyco said on Monday it had received a notice from the U.S. Internal Revenue Service stating that several […]

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IRS Updates Allowable Living Expense Standards for 2013

IRS Updates Allowable Living Expense Standards for 2013

The Internal Revenue Service released the 2013 updates to the Allowable Living Expense Standards on April 1. The ALE standards are used to reduce subjectivity in determining what a taxpayer may claim as basic living expenses necessary to avoid undue hardship when the taxpayer must delay full payment of a delinquent tax. The standard allowances […]

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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