Courses 2009 - 2010
LAW T 502 Federal Tax Controversies and Procedures
This course covers the whole range of taxpayer’s relationships with the Internal Revenue Service from filing returns through auditing the taxpayer’s return and the handling of any resulting controversy. Included will be requests for rulings and technical advice memoranda, periods of limitation and their mitigation, IRS deficiency procedures and conference procedures, transferee liability and the assertion of, and defense against, civil tax penalties. The course will close with issues relating to choice of forum with emphasis on Tax Court practice.