Tax Controversy Practice
This course will walk students through the representation of a client during various administrative and judicial proceedings concerning compliance with federal tax law. Students will become familiar with the rules for practicing before the Internal Revenue Service (“IRS”) as well as the Rules of Practice and Procedure for the United States Tax Court. In addition, students will consider ethical issues that arise while representing clients before the IRS. During the semester, students will advise their clients with respect to an IRS examination, prepare a Tax Court petition, draft other documents and filings associated with a Tax Court proceeding and the collections process, and prepare an administrative ruling request.
Each student will be responsible for weekly reading and research assignments as well as periodic written assignments including client communications, communications with the IRS, and Tax Court filings.