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Jurisdiction

No relief for taxpayer who received IRS notice after deadline for protesting it

No relief for taxpayer who received IRS notice after deadline for protesting it

Atuke vs. Commissioner of Internal Revenue, Order of Dismissal for Lack of Jurisdiction, Tax Court Docket No. 31680-15SL (Apr. 15, 2016). In an unpublished order for dismissal, the Tax Court has held that it had no jurisdiction to hear a taxpayer’s appeal, brought after the 30-day deadline, of IRS’s determination following a collection due process […]

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Similarity to related partnership’s issues didn’t preclude Tax Court jurisdiction

Similarity to related partnership’s issues didn’t preclude Tax Court jurisdiction

American Milling, LP, TC Memo 2015-192 The Tax Court has held that it had jurisdiction with respect to various issues contained in a Notice of Final Partnership Administrative Adjustment (FPAA) issued to a partnership that was a partner in a lower tier partnership. It rejected the taxpayer’s arguments that: a) the FPAA was a “reproduction” […]

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Tax Court upholds validity of FPAA & jurisdiction to hear partnership case

Tax Court upholds validity of FPAA & jurisdiction to hear partnership case

Green Gas Delaware Statutory Trust, TC Memo 2015-168 The Tax Court has concluded that the Final Partnership Administrative Adjustment (FPAA) issued by IRS to a trust taxed as a partnership was valid and that the Court had jurisdiction over the case. In so holding, the Court rejected the taxpayer’s challenges to the timing of IRS’s […]

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IRS Disagrees With Tax Court Ruling On Employment Status Jurisdiction; Issues Guidance

IRS Disagrees With Tax Court Ruling On Employment Status Jurisdiction; Issues Guidance

IRS’s Office of Chief Counsel has issued guidance on when to issue a Notice of Determination of Worker Classification (NDWC) under Code Sec. 7436 and how to handle docketed Tax Court cases when employment taxes are involved. This guidance was issued in light of a Tax Court opinion, SECC Corporation, (2014) 142 TC No. 12, […]

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IRS letter to whistleblower was a “determination” for Tax Court jurisdiction purposes

IRS letter to whistleblower was a “determination” for Tax Court jurisdiction purposes

Comparini, (2014) 143 TC No. 14 The Tax Court has ruled that it had jurisdiction to hear a claim for a whistleblower award where the whistleblowers filed their Tax Court petition within 30 days of receiving a letter from IRS that the Court ruled was a “determination” by IRS. The Court also concluded that the […]

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Tax Court upholds jurisdiction to determine status of refunds and if deficiency procedures apply

Tax Court upholds jurisdiction to determine status of refunds and if deficiency procedures apply

In Sotiropoulos v. Commissioner, (2014) 142 TC No. 151, the Tax Court has determined that it had jurisdiction to consider whether certain payments received by a U.S. citizen working abroad from a foreign taxing authority were in fact refunds under Code Sec. 905(c)(1)(C). IRS argued that the amounts were refunds and that it had the […]

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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