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Legal Memorandum

IRS won’t levy on Social Security disability insurance payments

IRS won’t levy on Social Security disability insurance payments

In a memo to its Collection staff, IRS’s Small Business/Self-Employed (SB/SE) Division has stated that it will not levy on Social Security disability insurance payments that are payable after Oct. 3, 2015.  Click here for IRS’s Small Business/Self-Employed Division memo “Federal Payment Levy Program – Exclude Disability Insurance Payments” (Oct. 7, 2015). Background. Code Sec. […]

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LB&I sheds light on when power generation property is considered “replaced” for 263(a) purposes

LB&I sheds light on when power generation property is considered “replaced” for 263(a) purposes

A recently released memorandum to all employees at IRS’s Large Business and International (LB&I) Division provides guidance to IRS examiners on how to determine when a major component pertaining to steam or electric generation property has been replaced under Reg. § 1.263(a)-3(k). The memo generally provides that a major component is considered to be replaced, […]

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Installment agreement request on post-petition liabilities rejected if taxpayer is in bankruptcy

Installment agreement request on post-petition liabilities rejected if taxpayer is in bankruptcy

In a memorandum, SBSE-05-0315-0033, “Processing Installment Agreement Requests for Post – Petition Liabilities when a Taxpayer is in Bankruptcy.” IRS’s Small Business/Self-Employed Division (SBSE) has advised its personnel that if a taxpayer is in bankruptcy, an installment agreement request on post-petition liabilities will no longer be accepted. Background. In the past, taxpayers in specific bankruptcy […]

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IRS clarifies “core qualifying activities” for tonnage tax exclusion purposes

IRS clarifies “core qualifying activities” for tonnage tax exclusion purposes

In Legal Advice Issued by Associate Chief Counsel, Internal Legal Memorandum 2013-005, IRS has concluded that while certain maintenance and repair undertaken by a qualifying vessel operator between the U.S. and a foreign place constitutes core qualifying activities under Code Sec. 1356(b), when such activity is undertaken at a port terminal or other stationary place, […]

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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