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Disguised Corporate Ownership

Court of Appeals affirms; partnership’s allocation of state credits to new partner was disguised sale

Court of Appeals affirms; partnership’s allocation of state credits to new partner was disguised sale

Route 231, LLC, (CA 4 1/8/2016) 117 AFTR 2d ¶ 2016-323 The Court of Appeals for the Fourth Circuit, affirming the Tax Court, has determined that the Code Sec. 707 disguised sale rules applied to a transaction involving a contribution of cash to a partnership by a party that the partnership alleged was a new […]

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Tax Court recharacterizes partnership’s allocation of state tax credits as disguised sale

Tax Court recharacterizes partnership’s allocation of state tax credits as disguised sale

SWF Real Estate LLC, Yellowfish Investments, Inc. Tax Matters Partner, TC Memo 2015-63   Following Fourth Circuit precedent, the Tax Court has determined that the Code Sec. 707 disguised sale rules applied to a transaction involving a contribution of cash to a partnership in exchange for an allocation of state tax credits. Click here for […]

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Court of Appeals for the Seventh Circuit rejects tax shelter organizer’s attempt to avoid tax on payments to his S corporation

Court of Appeals for the Seventh Circuit rejects tax shelter organizer’s attempt to avoid tax on payments to his S corporation

The Court of Appeals for the Seventh Circuit, affirming the Tax Court, has determined in Rogers v. Commissioner, (Court of Appeals 7th Cir.,  08/26/2013) 112 AFTR 2d ¶2013-5247, that a distressed asset/debt (DAD) tax shelter organizer had to report as income funds received by his solely owned S corporation as part of the shelter arrangement. […]

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Former Sevierville, Tenn. Resident Convicted of Tax Evasion

Former Sevierville, Tenn. Resident Convicted of Tax Evasion

As reported in the DOJ Press Release, the Justice Department and the Internal Revenue Service (IRS) announced that Jimmie Duane Ross of Lehi, Utah, and formerly of Sevierville, Tenn., was convicted today of five counts of tax evasion following a jury trial in the U.S. District Court for the Eastern District of Tennessee. According to […]

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Federal Court Permanently Bars California Lawyer from Tax Preparation and Giving Tax Advice

Federal Court Permanently Bars California Lawyer from Tax Preparation and Giving Tax Advice

Per the press release issued by the Department of Justice, entitled “Federal Court Permanently Bars California Lawyer from Tax Preparation and Giving Tax Advice,” a San Diego Tax Lawyer Allegedly Worked with CPA to Help Clients Evade Income Taxes and Circumvent Pension-Plan Rules.  Here’s the press release. A federal court in San Diego has permanently […]

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IRS Releases the Dirty Dozen Tax Scams for 2012

IRS Releases the Dirty Dozen Tax Scams for 2012

IRS Releases the Dirty Dozen Tax Scams for 2012 IRS YouTube Videos: Dirty Dozen: English | Spanish | ASL WASHINGTON –  The Internal Revenue Service recently issued its annual “Dirty Dozen” ranking of tax scams, reminding taxpayers to use caution during tax season to protect themselves against a wide range of schemes ranging from identity […]

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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