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This seminar will cover a variety of issues that arise in civil tax controversies and litigation between taxpayers and the Internal Revenue Service, which may take place in any of three federal courts, including the United States Tax Court. Topics that will be covered include an overview of the tax controversy process; a variety of procedural issues that arise in Tax Court litigation, include the controversy over confidential factfinding; and aspects of the strategic choice between the Tax Court and the "refund" fora. The course will also cover certain aspects of tax administration, such as issues that arise in tax compliance and enforcement of the tax laws. A general familiarity with the Internal Revenue Code is helpful for this course. Therefore, prior or concurrent enrollment in Introduction to Income Taxation (or equivalent tax background, as determined by the instructor) is required.
Find the course Web site at webcourses.lexisnexis.com.
The casebook for this course is Lederman & Mazza, Tax Controversies: Practice and Procedure (3rd ed., forthcoming 2008) (chapters of the manuscript will be posted in the "Course Documents" area on the course Web site, so there is no need to purchase a book for this class). Additional readings are listed on the syllabus and are either available in the "Course Documents" area of the course website or are listed with URLs to obtain them on the Web.
The reading assignment for the first class consists of brief excerpts from Chapters 1 (including Tax Controversy Chart), 4, 7, 9, 10 and 12 of Tax Controversies: Practice & Procedure. The statutes listed as assigned reading in the chapters are not assigned.
Indiana University Maurer School of Law is accredited by the American Bar Association
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