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Mitigation Provisions

Court of Appeals – Different positions in two tax years didn’t meet “inconsistent position” mitigation requirement

Court of Appeals – Different positions in two tax years didn’t meet “inconsistent position” mitigation requirement

Illinois Lumber and Material Dealers Association Health Insurance Trust, (CA 8 7/23/2015) 116 AFTR 2d ¶2015-5079 The Court of Appeals for the Eighth Circuit has held that the fact that IRS held a position in a closed tax year that was inconsistent with a position that it held in an open tax year was insufficient […]

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Equitable recoupment, mitigation no help to misclassified employee

Equitable recoupment, mitigation no help to misclassified employee

The Tax Court decided in Karagozian v. Commissioner, T.C. Memo 2013-64, that an employee who underpaid his 2008 income tax, and overpaid his 2002-2008 FICA tax, as a result of his employer misclassifying him as self-employed, couldn’t use the equitable recoupment or mitigation doctrines to offset his underpayment with any of the previous year overpayments. […]

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Delays by IRS in the processing of net operating loss (NOL) cases has resulted in the agency making millions of dollars annually in unnecessary interest payments to taxpayers

Delays by IRS in the processing of net operating loss (NOL) cases has resulted in the agency making millions of dollars annually in unnecessary interest payments to taxpayers

TIGTA’s report entitled “Delays in processing net operating (NOL) loss cases resulted in millions of dollars in unnecessary interest payments,” is very topical for a few reasons. For one thing, I have clients who have pending refund claims, and have been delayed in receiving their refunds.  They are actually quite surprised to learn that the […]

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Mitigation provisions didn’t allow a taxpayer an NOL discovered on audit Chief Counsel Advice 201208027

Mitigation provisions didn’t allow a taxpayer an NOL discovered on audit Chief Counsel Advice 201208027

Mitigation provisions didn’t allow a taxpayer an NOL discovered on audit Chief Counsel Advice 201208027 In Chief Counsel Advice (CCA), IRS has concluded that the mitigation provisions under Code Sec. 1311 through Code Sec. 1314 didn’t allow a barred refund after an audit resulted in an increased net operating loss (NOL) that was properly carried […]

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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