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Federal Tax Lien

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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Wife couldn’t block IRS collection of husband’s tax via liens on community property

Wife couldn’t block IRS collection of husband’s tax via liens on community property

Smith, (DC WA 2/8/2016) 117 AFTR 2d ¶ 2016-412 A district court has rejected several arguments made by a wife in a community property state, that IRS not be able to foreclose its tax lien on the couple’s community property to pay taxes owed by her husband. Background. If IRS determines that there is a deficiency […]

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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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Tax Court upholds IRS’s imposition of penalties against “corporation sole” promoters

Tax Court upholds IRS’s imposition of penalties against “corporation sole” promoters

Gardner, (2015) 145 TC No. 6 The Tax Court has upheld IRS’s imposition of a Code Sec. 6700 abusive tax shelter promoter penalty against two married corporation sole promoters. The Court concluded that a prior district court decision collaterally estopped them from disputing that they engaged in conduct subject to the penalty and rejected the […]

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IRS liable for litigation costs: taxpayer owned property, so lien against ex-husband invalid

IRS liable for litigation costs: taxpayer owned property, so lien against ex-husband invalid

Baker (DC NH 1/8/2015) 115 AFTR 2d ¶ 2015-323 A district court has granted an ex-wife’s request for an award of litigation costs because it found that IRS’s argument—that it had a lien against her ex-husband with respect to real property that he had transferred to her pursuant to the couple’s divorce—was based on an […]

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