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Office of Appeals

New guidance explains IRS’s procedures for administrative appeals of docketed cases

New guidance explains IRS’s procedures for administrative appeals of docketed cases

Rev Proc 2016-22, 2016-15 IRB IRS has issued a Revenue Procedure to update its description of the administrative appeals process in cases docketed in the Tax Court. Background. Rev Proc 87-24, 1987-1 CB 720 describes IRS’s administrative appeals process in cases docketed in the Tax Court. The Office of Chief Counsel (Counsel) is charged with the […]

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IRS updates its procedures for administrative appeals of docketed cases

IRS updates its procedures for administrative appeals of docketed cases

Rev Proc 2016-22, 2016-15 IRB IRS has issued a Revenue Procedure to update its description of the administrative appeals process in cases docketed in the Tax Court. Background. Rev Proc 87-24, 1987-1 CB 720 describes IRS’s administrative appeals process in cases docketed in the Tax Court. The Office of Chief Counsel (Counsel) is charged with the […]

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Joint Explanatory Statement of the Committee of Conference – Tax provisions in the “Fixing America’s Surface Transportation (FAST) Act”

Joint Explanatory Statement of the Committee of Conference – Tax provisions in the “Fixing America’s Surface Transportation (FAST) Act”

Joint Explanatory Statement of the Committee of Conference On December 3, one day before the expiration of the previously-passed temporary funding measure, both chambers of Congress passed H.R.22, the “Fixing America’s Surface Transportation (FAST) Act”. The bill was sent to President Obama for his expected signature. In addition to authorizing federal surface transportation programs through […]

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IRS will update its procedures for administrative appeals of docketed cases

IRS will update its procedures for administrative appeals of docketed cases

Notice 2015-72, 2015-44 IRB In a Notice, IRS has provided a proposed revenue procedure which will update its published description of the IRS administrative appeals process in cases docketed in the Tax Court. Background. Prop Reg § 601.106(c)(3) and Rev Proc 87-24, 1987-1 CB 720, describe IRS’s administrative appeals process in cases docketed in the Tax […]

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IRS Ends Appeals Arbitration Program

IRS Ends Appeals Arbitration Program

Rev Proc 2015-44, 2015-38 IRB Noting the lack of success of the program over its 14-year history, IRS has announced that it is ending its Appeals arbitration program, effective Sept. 21, 2015. Background. Code Sec. 7123(b)(2) requires that IRS establish a pilot program under which a taxpayer and IRS’s Appeals division (Appeals) may jointly request binding […]

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Tax Court upholds IRS’s imposition of penalties against “corporation sole” promoters

Tax Court upholds IRS’s imposition of penalties against “corporation sole” promoters

Gardner, (2015) 145 TC No. 6 The Tax Court has upheld IRS’s imposition of a Code Sec. 6700 abusive tax shelter promoter penalty against two married corporation sole promoters. The Court concluded that a prior district court decision collaterally estopped them from disputing that they engaged in conduct subject to the penalty and rejected the […]

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Washington Alert – TIGTA Report on IRS and ACA; Taxpayer ‘fundamental rights’; CBO Report on SSA benefits

Washington Alert – TIGTA Report on IRS and ACA; Taxpayer ‘fundamental rights’; CBO Report on SSA benefits

During the second half of fiscal year 2014, the Treasury Inspector General for Tax Administration (TIGTA) completed 75 audits and 1,636 investigations, according to a report the agency recently released. (Semiannual Report to Congress – April 1, 2014-Sept. 30, 2014) TIGTA’s combined audit and investigation efforts “recovered, protected and identified monetary benefits totaling $16.6 billion,” […]

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The Office of Appeals Continues To Experience Difficulties In The Handling Of Collection Due Process Cases

The Office of Appeals Continues To Experience Difficulties In The Handling Of Collection Due Process Cases

TIGTA reports “The Office of Appeals Continues To Experience Difficulties In The Handling Of Collection Due Process Cases.” In this year’s audit, TIGTA continued to identify the same deficiencies in the IRS’s processing of Collection Due Process cases as previously reported. Specifically, the Office of Appeals did not always classify taxpayer requests properly and, as […]

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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