LAW G534: State & Local Tax Controversy
Summer 2022 • Section 51

Course Description

This course will examine state and local tax controversies, including audits, administrative and judicial appeals, and important constitutional challenges related to state and local taxes. The first half of the course will focus on managing a state tax audit examination and challenging an audit assessment through the appeals process. Students will analyze common corporate income tax and sales and use tax issues raised in audit examinations. They will also learn the benefits of voluntary disclosure agreements and amnesty programs as options for coming into compliance with state and local tax filing obligations. The second half of the course will focus on constitutional challenges to current state and local tax issues, including issues related to the Commerce Clause, Due Process Clause, Equal Protection Clause, Supremacy Clause and even the First Amendment, which can weave its way into state and local tax cases. This half of the course will also address the prospectivity, retroactivity and remedy that occur once a tax is found to be unconstitutional. Towards the end of the course, students will apply what they have learned throughout the semester in a mock administrative hearing.

Book List/Materials