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Constructive receipt of income

Court of Appeals, 5th Circuit affirms; shareholder had constructive receipt of funds from buyout of her shares

Court of Appeals, 5th Circuit affirms; shareholder had constructive receipt of funds from buyout of her shares

Santangelo, (CA 5 12/27/2014) 114 AFTR 2d ¶ 2014-5572 The Court of Appeals for the Fifth Circuit has affirmed a district court holding that an individual was in constructive receipt of income from a stock sale triggered by a merger in 2006 even though neither she nor her daughter, who held a power of attorney, […]

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Individual received income from merger-triggered stock sale before her death

Individual received income from merger-triggered stock sale before her death

In Santangelo v. U.S., (DC MS 03/19/2014) 113 AFTR 2d ¶ 2014-649, a district court has held that an individual was in constructive receipt of income from a stock sale triggered by a merger in 2006 even though neither she nor her daughter, who held a power of attorney, attempted to access the funds before […]

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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