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Valuation misstatement penalty

Gross valuation misstatement penalty applied where partnership inflated basis of its chemical plant

Gross valuation misstatement penalty applied where partnership inflated basis of its chemical plant

Chemtech Royalty Associates v. U.S., (DC LA 5/8/2015) 115 AFTR 2d ¶2015-732 On remand from the Court of Appeals for the Fifth Circuit, a district court has held that the 40% gross valuation misstatement penalty applied in respect to a tax shelter transaction that involved overstating the basis of a chemical plant that had, for […]

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Court settles on original value in resolving valuation dispute with many changed positions

Court settles on original value in resolving valuation dispute with many changed positions

Estate of Franklin C. Adell, TC Memo 2014-155 The Tax Court has determined the estate tax value of a decedent’s 100% ownership interest in a corporation to be the amount originally reported by the estate. It rejected a lower value subsequently sought by the estate and a higher value claimed by IRS. The Court also […]

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Court of Appeals for the Seventh Circuit upholds 40% penalty where transaction lacked economic substance; circuit split widens

Court of Appeals for the Seventh Circuit upholds 40% penalty where transaction lacked economic substance; circuit split widens

The Court of Appeals for the Seventh Circuit, in Superior Trading LLC, et al, v. Commissioner, (CA 7 8/26/2013) 112 AFTR 2d ¶ 2013-5248, has affirmed a Tax Court decision that upheld IRS’s disallowance of losses claimed in association with a distressed asset/debt tax shelter and its imposition of a 40% gross valuation misstatement penalty. […]

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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