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Internal Revenue Manual (IRM)

New SB/SE memorandum modifies certain employment tax audit procedures

New SB/SE memorandum modifies certain employment tax audit procedures

IRS has issued a memorandum to examiners in the Small Business/Self-Employed (SB/SE) division to clarify and update their responsibilities regarding checking that returns were filed (filing checks) and the scope of all employment tax examinations. Click here for SBSE-04-0915-0058 on “Procedures for Required Filing Checks and Scope of Employment Tax Examinations”. Background. Part 4.23 of the […]

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Audit Guide Provides Roadmap For Reviewing Nonqualified Deferred Comp Plans

Audit Guide Provides Roadmap For Reviewing Nonqualified Deferred Comp Plans

IRS has updated its Audit Techniques Guide (ATG) focusing on nonqualified deferred comp (NQDC) plans. It provides auditors with a roadmap to some of the issues in this area, and what to look for when reviewing such plans. Although intended to provide instruction to IRS examiners, the ATG provides insight to the issues that might […]

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IRS Reviews Consequences of Foreclosures Involving Nonrecourse or Recourse Debt

IRS Reviews Consequences of Foreclosures Involving Nonrecourse or Recourse Debt

IRS recently issued an Audit Techniques Guide (ATG) on foreclosure, a complex topic that has swamped practitioners and IRS alike in recent years due to the extended fallout from the subprime mortgage crisis. One of the many topics of interest is the foreclosure of properties with nonrecourse or recourse mortgages. This article reviews the ATG’s […]

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What is the value and utility of regs, rulings, and other IRS documents? – Part II

What is the value and utility of regs, rulings, and other IRS documents? – Part II

IRS issues a wide variety of documents every week, some of which are written for public release and others of which are for IRS’s internal use but are ultimately released under the Freedom of Information Act. Whether written for internal or public use, IRS administrative pronouncements vary in precedential value and utility. This 2-part Practice […]

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New LB&I directive clarifies information document request procedures

New LB&I directive clarifies information document request procedures

IRS’s Large Business and International division (LB&I) has issued an updated directive on the requirements for issuing and enforcing information document requests (IDRs). Among other things, the new directive states that examiners and specialists have discretion, as warranted by the circumstances, to grant an extension to taxpayers who either fail to respond to an IDR […]

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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