LLM 319

Federal Tax Procedure

3 Unit(s)

A survey course in the procedural aspects of dealings between taxpayers and their representatives on the one hand and the Internal Revenue Service, IRS Office of Professional Responsibility, the Office of the Chief Counsel for the Internal Revenue Service, and the Tax Division of the Department of Justice on the other hand. It will assist you to understand and prepare to handle practical issues involving your and your clients’ or employer’s duties, powers, responsibilities, liabilities, privileges, and ethical obligations arising in federal tax practice, including access to information; IRS examinations and appeals; deficiency assessments; interest on underpayments and overpayments; penalties (civil and criminal) against taxpayers, their representatives, and their tax return preparers; statutes of limitations on assessment and collection of taxes and penalties and criminal tax prosecutions; and refund and collection of federal income, estate and gift taxes. Cross-listed with and equivalent to TA 319. (JD students seeking to enroll must obtain the approval of the program director.)