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Res judicata

Court of Appeals: Estate couldn’t rely on res judicata to save refund claims

Court of Appeals: Estate couldn’t rely on res judicata to save refund claims

Batchelor-Robjohns, et al v. U.S., (CA 11, 06/05/2015) 115 AFTR 2d ¶2015-804 The Court of Appeals for the Eleventh Circuit, reversing a district court’s grant of summary judgment on this issue, has rejected an Estate’s attempt to invoke res judicata in order to prevent IRS from assessing additional tax stemming from a now-deceased individual’s sale […]

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Res judicata barred IRS from offsetting refund by tax due for earlier year and no relief under equitable recoupment theory

Res judicata barred IRS from offsetting refund by tax due for earlier year and no relief under equitable recoupment theory

In Batchelor-Robjohns v. U.S., (DC FL 11/13/2013) 112 AFTR 2d ¶ 2013-5488, a district court has held that IRS erroneously determined that a now-deceased individual failed to report $5.8 million in income on his 2000 income tax return. It also held that res judicata barred IRS from offsetting the refund due for 2000 by the […]

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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