TAX PRACTICE AND PROCEDURE (TAXN7115)
2 credits. Lecture.
Prerequisite: Federal Income Taxation.

This course includes: the statute of limitations, burden of proof and tax penalties; equitable doctrines; administrative procedures, including audits, appeals, request for rulings and technical advice; settlements; closing agreements and compromises. It undertakes an in-depth analysis of the Internal Revenue Service and the functions and responsibilities of its various divisions. It studies choice of forum in civil tax litigation, including the tax court, district court, and claims court. It surveys tax court litigation, including the statutory deficiency notice and tax court petition and other jurisdictional prerequisites; tax refund claims and litigation; the collection process, including assessment of tax, jeopardy assessment, levy and distraint, the tax lien and its priorities, restraining tax collection, the innocent spouse rules and transferee and fiduciary liability.