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Trade or business

Aircraft held for productive use in a trade or business and qualify for tax-free exchange

Aircraft held for productive use in a trade or business and qualify for tax-free exchange

Chief Counsel Advice 201601011 In Chief Counsel Advice (CCA), IRS has concluded that aircraft that a partnership initially held and aircraft that it received in exchange for the initial aircraft were held “for productive use in a trade or business” for purposes of qualifying for a tax-free exchange under Code Sec. 1031, where the aircraft—which […]

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Tax Court – Mortgage-related dispute kept foreclosure from being passive activity disposition

Tax Court – Mortgage-related dispute kept foreclosure from being passive activity disposition

Herwig, TC Memo 2014-95. The Tax Court has ruled that where taxpayer’s limited liability company’s (LLC’s) passive activity consisted of the ownership of two rental properties, those properties were foreclosed upon by the lender and sold at foreclosure sales, but there were pending counterclaims between taxpayer and the lender with respect to deficiency judgments on […]

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Tax Court – Taxpayer who says he intended to flip real estate wasn’t in a trade or business

Tax Court – Taxpayer who says he intended to flip real estate wasn’t in a trade or business

Ohana, TC Memo 2014-83. The activities of a taxpayer who owned two rental properties in Israel, then bought two properties in the U.S., lived in one of the U.S. properties, then rented it out and moved into the other U.S. property, weren’t a trade or business, despite his claimed intention to make money from flipping […]

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Self-proclaimed “book author” couldn’t deduct costs of world travel

Self-proclaimed “book author” couldn’t deduct costs of world travel

In Oros v. Commissioner, (CA 9 12/31/2013) 113 AFTR 2d ¶ 2014-311, the Ninth Circuit Court of Appeals, affirming the Tax Court, has determined that a full-time employee of a computer/technology corporation wasn’t entitled to deduct the world travel costs that he allegedly incurred in furtherance of a book that he intended to write and […]

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Taxpayer’s trading activities insufficient to establish trade or business

Taxpayer’s trading activities insufficient to establish trade or business

The Tax Court, in Nelson v. Commissioner, T.C. Memo. 2013-259, has determined that a mortgage broker wasn’t in the trade or business of trading securities and upheld IRS’s disallowance of over $800,000 in expenses purportedly claimed in connection with these activities over two tax years. The Court also determined that the taxpayer was liable for […]

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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