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Constructive Dividend

Tax Court holds that a corporation’s provision of ‘at-cost services’ to sole owner wasn’t a constructive dividend

Tax Court holds that a corporation’s provision of ‘at-cost services’ to sole owner wasn’t a constructive dividend

The Tax Court has held, in Welle v. Commissioner, (2013) 140 T.C. 19, that the sole owner of a corporation didn’t receive a constructive dividend as a result of the corporation’s provision of construction-related services to him without charging its standard profit margin. The Court rejected IRS’s argument that the corporation’s forgone profits gave rise […]

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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