Tax Procedure Syllabus - Fall 2019 (3).pdf - Professor Henry C Cheng Tax Procedure Litigation and Administrative Practice Fall 2019 TAX PROCEDURE

Tax Procedure Syllabus - Fall 2019 (3).pdf - Professor...

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Professor Henry C. Cheng Tax Procedure: Litigation and Administrative Practice Fall 2019 T AX P ROCEDURE : L ITIGATION AND A DMINISTRATIVE P RACTICE I. Introduction Welcome to Tax Procedure: Litigation and Administrative Practice. In this 2-unit course we will explore the critical rules (based on statutes, administrative pronouncements, and case law) that drive the administration of the federal tax system, as well as policy and strategic considerations in the application of these rules. Perhaps to your surprise, these rules and considerations are not only critical to those who want to become successful tax litigators, but they are also relevant and interesting to tax lawyers who analyze complex transactions and even to those who formulate tax policy. We will explore these issues by working through the progression of a tax dispute between a taxpayer and the Internal Revenue Service. Remember tax controversy is the last stage of a “tax lifecycle”: planning, accounting/provision, compliance, audit and administrative review, and litigation . This final phase is where the “correct tax” is determined. Thus, it is particularly important for tax litigators representing either the Government or taxpayers in an adversarial system to bear in mind two issues as they advocate for their clients: (1) the fair administration of the Internal Revenue Code, and (2) the safeguarding of the integrity of the Internal Revenue Code. These issues are sometimes harmonious but sometimes at odds with each other.
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