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Loss carryback

Private Letter Ruling – Application of overpayment to overstated loss carryback was a credit, not a refund

Private Letter Ruling – Application of overpayment to overstated loss carryback was a credit, not a refund

PLR 201548019 In a Technical Advice Memorandum (TAM), IRS has concluded that, where a taxpayer has a large overpayment for a tax year, and also has a small tax liability for that year as a result of an overstated loss carryback to that year, overpayment interest on the amount of that liability only runs until […]

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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