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Ponzi Scheme

California Investment Manager Sentenced to 225 Months in Prison for $33 Million Fraud Scheme

California Investment Manager Sentenced to 225 Months in Prison for $33 Million Fraud Scheme

California Investment Manager Sentenced to 225 Months in Prison for $33 Million Fraud Scheme, as reported in the DOJ Press Release. A California investment manager was sentenced yesterday to serve 225 months in prison for orchestrating a $33 million Ponzi scheme resulting in $15.2 million in losses to investors. Assistant Attorney General Leslie R. Caldwell […]

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IRS provides non-safe-harbor guidance for Ponzi scheme victims

IRS provides non-safe-harbor guidance for Ponzi scheme victims

In Program Manager Technical Advice 2013-003, IRS has provided guidance to persons who have “phantom income” from a fraudulent investment scheme and who do not or cannot use the safe harbor procedures provided in Rev Proc 2009-20, 2009-14 IRB 749. Click here for the text of Program Manager Technical Assistance 2013-003. Program Manager Technical Advice. […]

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Draft Form 4684 has new section for claiming certain Ponzi scheme losses

Draft Form 4684 has new section for claiming certain Ponzi scheme losses

IRS has posted on its website draft 2013 Form 4684, Casualties and Thefts, and accompanying draft instructions. The draft form includes a new section for claiming certain theft loss deductions due to a Ponzi-type investment scheme.  Click here for the draft 2013 Form 4684, Casualties and Thefts.  Click here for the draft instructions to the […]

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Ponzi scheme victims allowed theft losses despite lack of direct investment with perpetrator

Ponzi scheme victims allowed theft losses despite lack of direct investment with perpetrator

In Chief Counsel Advice (CCA) 201213022, the IRS has determined that Ponzi scheme losses suffered by taxpayers are theft losses under Code Sec. 165, even though the taxpayers invested through individuals other than the perpetrator. IRS found that the facts showed that there was privity between the taxpayers and the perpetrator. Background. A taxpayer can […]

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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