Course Details

Tax Audits, Appeals, and Litigation

This course considers the role of the attorney in effectively representing a client in the four stages of dealing with the Internal Revenue Service--audit preparation, audit management, administrative appeals, and litigation. For example, the audit preparation segment will consider the identification and preparation of technical issues, preservation of facts and documents, and preservation of the privileges of confidentiality. The audit management segment will consider the Service's fact-gathering authority, responding to proposed adjustments in tax liability raised by the Service, procedures and strategies for dealing with the Service, requesting competent authority relief, and achieving finality for settled issues. The administrative appeals segment will consider the procedures and strategies available to the taxpayer to present its position to the Service's Appeals Office, the highest level of administrative appeal within the Service, including preparation of an effective protest and strategy for dealing with the Appeals Office. Finally, the litigation segment will consider the litigation process from beginning to end, including choice of the best litigation forum, the discovery process, the selection and use of expert witnesses, the trial process, and appellate review of an adverse decision of the trial court. All segments of the course will consider strategies and explore the pros and cons of the various alternative and early dispute resolution procedures that are available to the parties, including private letter rulings, advance pricing agreements, pre-filing agreements, technical advice, "fast track," early referral to appeals, rapid appeals process, mediation and arbitration. Registration Requirements: Basic Federal Income Tax is a pre-requisite for JD candidates. The class is not a biddable class for JD and non-Tax LLM students. JD and non-Tax LLM students may only enroll in this class during the drop/add period with the permission of the instructor. Evaluation Method: Final Examination.

Catalog Number: TAXLAW 676
Practice Areas: Taxation Practice Area
Additional Course Information: LLM tax course open to JD students,  Tax Program Course


Course History

Spring 2018
Title: Tax Audits, Appeals, and Litigation
Faculty: Aland, Robert H. (courses | profile)
Section: 1     Credits: 2.0
Capacity: 18     Actual: 6

Spring 2016
Title: Tax Audits, Appeals, and Litigation
Faculty: Aland, Robert H. (courses | profile)
Section: 1     Credits: 2.0
Capacity: 22     Actual: 6