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Restitution

Pending appeal of criminal conviction motion doesn’t affect timing of restitution assessment

Pending appeal of criminal conviction motion doesn’t affect timing of restitution assessment

Chief Counsel Advice 201616011 In an emailed Chief Counsel Advice, IRS has concluded that the fact that an individual has a pending appeal of his motion to vacate his criminal conviction does not affect IRS’s ability to assess the amount of criminal restitution owed it under a court order. Background. 18 USC 3556 provides for mandatory […]

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Restitution paid to government as part of business crime plea deal was deductible

Restitution paid to government as part of business crime plea deal was deductible

PLR 201528026 In a private letter ruling, IRS has held that a principal in a business could deduct the amount he paid to the U.S. government as restitution, as part of a plea deal resulting from his pleading guilty to a crime committed in the course of his employment.  Click here for the PLR. Background. […]

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No deduction for restitution amount paid to avoid criminal prosecution

No deduction for restitution amount paid to avoid criminal prosecution

Chief Counsel Advice 201513003 In emailed Chief Counsel Advice (CCA), IRS has held that a payment a taxpayer made to the U.S., in lieu of proceedings that would result in criminal and/or civil forfeiture for fraud, was nondeductible as a fine or similar penalty notwithstanding that the payment was earmarked for restitution to the victims […]

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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