LAW G531: Tax Procedure
Summer 2023 • Section 51

Course Description

This course will provide an overview of tax controversies before the Internal Revenue Service during the administrative stage through the commencement of litigation. Taught from a practical perspective, students will learn how to resolve disputes over what is often clients’ largest expense -- taxes. Students will examine statutes, regulations, and case law, and they will participate in simulated exercises involving mock IRS notices and transcripts. The course will cover the assessment of tax deficiencies, civil penalties, statute of limitation issues, tax collection issues, claims for refund, discharging taxes in bankruptcy, appeals conferences, joint liability issues, trust fund assessments, obligations of practitioners, and taxpayers’ rights. At the end of this course, students should understand: 1) the organizational structure and authority of the Internal Revenue Service in administering the Internal Revenue Code and collecting federal taxes, 2) the procedural rights of taxpayers to contest a proposed assessment and claim for refund, 3) taxpayer options in resolving collection issues and contesting unreasonable enforcement actions, and 4) how to strategically think about a taxpayer’s case to resolve a pending tax issue and minimize his/her exposure to additional civil tax issues (and potential criminal issues) before the Internal Revenue Service.

Book List/Materials