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Promoter fraud

Tax shelter promoter penalty isn’t divisible tax for full-payment rule

Tax shelter promoter penalty isn’t divisible tax for full-payment rule

Pfaff v. U.S., (DC 3/10/2016) 117 AFTR 2d ¶ 2016-507 A district court has concluded that the Code Sec. 6707 tax shelter promoter penalty isn’t a divisible tax. Accordingly, where the taxpayer did not pay the full amount of the penalty assessed by IRS, the district court did not have jurisdiction to hear the taxpayer’s […]

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IRS narrows requirement to file schedule m-3 to avoid penalties

IRS narrows requirement to file schedule m-3 to avoid penalties

Rev Proc 2016-13, 2016-4 IRB 290 IRS has issued a Revenue Procedure that contains IRS’s annual update of procedures that taxpayers must follow in order to meet the requirements for adequate disclosure that reduce the substantial understatement accuracy-related penalty and eliminate the preparer understatement penalty for unreasonable positions. The new Revenue Procedure eliminates the need […]

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Court of Appeals – promoter’s fraudulent intent insufficient to keep limitations period open

Court of Appeals – promoter’s fraudulent intent insufficient to keep limitations period open

BASR Partnership v. U.S., (Fed CA 7/290/2015) 116 AFTR 2d ¶2015-5100 The Court of Appeals for the Federal Circuit, affirming the Court of Federal Claims, has determined that there can be a suspension of the three-year limitation period for fraud under Code Sec. 6501(c)(1) only when the taxpayer, and not a third party, acts with […]

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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