Details

Considers the procedural issues encountered in tax cases at the administrative level and at the start of litigation, including the structure of the Internal Revenue Service, filing requirements, statutes of limitation, mitigation provisions, interest calculations, civil penalties, audit procedures, deficiency notices, choice of forum, administrative protests, closing and compromise agreements, claims for refund, and tax liens and collection mechanisms. This is a tax procedure course that does not overlap with the Tax Policy and Procedure seminar. Pre-requisite: Not open to second year JD students who are not enrolled in the Joint Degree Program without the permission of the instructor. Basic Federal Income Tax is a pre-requisite for JD candidates.