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Merger

Shareholder-Employee Received Both Ordinary Income And Capital Gain From Merger

Shareholder-Employee Received Both Ordinary Income And Capital Gain From Merger

Brinkley, TC Memo 2014-227 The Tax Court has ruled that where (1) a shareholder-employee of a corporation had continually expressed a desire that his ownership percentage in the corporation not dip below 3%, (2) the corporation agreed to meet that desire, (3) at the time the corporation merged, his percentage was only 0.8%, and (4) […]

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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