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Uniform Capitalization (UNICAP) rules

Court of Appeals 2nd Circuit: taxpayer didn’t qualify for small reseller’s exception to UNICAP rules

Court of Appeals 2nd Circuit: taxpayer didn’t qualify for small reseller’s exception to UNICAP rules

City Line Candy & Tobacco Corp. v. Comm. (CA 2, 9/30/2015) 116 AFTR 2d ¶ 2015-5293 The Court of Appeals for the Second Circuit, affirming the Tax Court, has concluded that a reseller and wholesaler of cigarettes couldn’t rely on the small reseller’s exception to the Code Sec. 263A uniform capitalization (UNICAP) rules because it […]

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Custom homebuilders subject to same UNICAP rules as spec builders

Custom homebuilders subject to same UNICAP rules as spec builders

The Tax Court has held, in Frontier Custom Builders, Inc., v. Commissioner, TC Memo 2013-231, that a custom homebuilder is subject to the Code Sec. 263A uniform capitalization (UNICAP) rules in the same way that a speculative homebuilder is. It rejected the taxpayer’s argument that custom homebuilding is centered around sales and marketing, and not […]

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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