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Distributions

Chief Counsel Advice determines tax treatment of S corp’s disallowed loss from property distribution

Chief Counsel Advice determines tax treatment of S corp’s disallowed loss from property distribution

Chief Counsel Advice 201421015. In Chief Counsel Advice (CCA), IRS has concluded that an S corporation’s disallowed Code Sec. 311(a) loss will be treated as nondeductible, noncapital expenses under Code Sec. 1367(a)(2)(D). Accordingly, the Code Sec. 311(a) loss will reduce shareholders’ bases in S corporation stock, and the S corporation must reduce its accumulated adjustments […]

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Court of Appeals for the Seventh Circuit rejects tax shelter organizer’s attempt to avoid tax on payments to his S corporation

Court of Appeals for the Seventh Circuit rejects tax shelter organizer’s attempt to avoid tax on payments to his S corporation

The Court of Appeals for the Seventh Circuit, affirming the Tax Court, has determined in Rogers v. Commissioner, (Court of Appeals 7th Cir.,  08/26/2013) 112 AFTR 2d ¶2013-5247, that a distressed asset/debt (DAD) tax shelter organizer had to report as income funds received by his solely owned S corporation as part of the shelter arrangement. […]

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Shareholder dispute didn’t shift beneficial interest of S corp shares

Shareholder dispute didn’t shift beneficial interest of S corp shares

The Tax Court, in Kumar v. Commissioner, T.C. Memo. 2013-184, has held that a doctor with a minority ownership interest in a medical practice organized as an S corporation, who was excluded by the majority owner from participation in the corporation’s activities, was not deprived of the economic benefit of his share ownership and was […]

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Distributions from S corporation to its president were wages, not loan repayments

Distributions from S corporation to its president were wages, not loan repayments

The Tax Court has held in Glass Blocks Unlimited v. Commissioner, T.C. Memo 2013-180, that distributions from an S corporation to its president/sole shareholder were taxable wages. IRS’s determination that the president was an employee was uncontested, and the S corporation failed to show that any portion of the distributions reflected repaid loans or that […]

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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