Contact Paul +

Time limit is exhausted. Please reload CAPTCHA.

equitable estoppel

Tax Court – State court decision on transfers between couple as gifts didn’t collaterally estop IRS

Tax Court – State court decision on transfers between couple as gifts didn’t collaterally estop IRS

Blagaich, TC Memo 2016-2 The Tax Court has concluded that a taxpayer couldn’t assert collateral estoppel against IRS and rely on a State court decision in a lawsuit between her and her ex-boyfriend that cash and property given to her by him were nontaxable gifts under Code Sec. 102(a). In addition, the Court held that […]

Read the full article →

Partnership’s statute of limitations period was validly extended

Partnership’s statute of limitations period was validly extended

In Peking Investment Fund, LLC, v. Commissioner, T.C. Memo. 2013-288, the Tax Court has ruled that consents to extend the statute of limitations (statute) executed by a representative of a partnership on behalf of the partnership were valid notwithstanding the fact that he was not a tax matters partner (TMP). Background – extension of statute […]

Read the full article →
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.

Read More

Connect With Paul on Social Media

Practice Areas & Information

Certifications &
Associations
Member CA Bar Member Orange County Bar US Tax Court Attorney