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Sale of assets

Tax Court applies Code Sec. 356(c) to determine gain and loss in merger transaction

Tax Court applies Code Sec. 356(c) to determine gain and loss in merger transaction

Tseytin, TC Memo 2015-247 The Tax Court has concluded that a shareholder, who purchased a block of stock from another shareholder to effectuate a corporate merger, should be treated as the owner of that block of stock and not merely as an agent or nominee who held the stock for another. Further, in determining the […]

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Tax Court holds assets transferred to newly incorporated former proprietorship were capital contributions

Tax Court holds assets transferred to newly incorporated former proprietorship were capital contributions

Bell, TC Memo 2015-111 The Tax Court has held that a couple’s transfer of the assets of their sole proprietorship real estate brokerage to a newly formed corporation of which they owned all of the stock was a capital contribution, not a sale of assets, to the corporation. Background. Whether an advance to a corporation is […]

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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