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Fall 2021
5292 Tax Procedure - VASQUEZ, JR.- 11265

Professor(s): Juan Vasquez (ADJUNCT)

Credits: 2

Course Areas: Taxation 

Time: 5:30p-7:30p  T  Location: 121  TUII

Course Outline: This class covers the procedural aspects of dealing with the Internal Revenue Service, the
agency that administers the federal tax system. The focus is from the private practitioner's
perspective in assisting clients navigate the daunting administrative requirements. The class offers
the following principal subjects:
• Administrative Organization of the IRS.
• The Regulatory Process -- IRS Pronouncements such as Regulations, Revenue Rulings,
Technical Advice Memoranda and Private Letter Rulings
• IRS Audits, including use of IRS Administrative Summonses and Statutes of Limitations
Penalties (Civil and Fraud) and Interest
• IRS Administrative Appeals
• Civil Tax Litigation with the IRS -- Tax Court, District Court, Court of Federal Claims,
Courts of Appeals and United States Supreme Court.
• Collections, including IRS liens and levies
• Federal Tax Crimes, Methods of Proof and Investigative Techniques
• Ethics of Practice in the Tax Procedure Context

Course Syllabus: Syllabus revised 8/24/21

Course Notes: DistanceEd  The instructor for this course has expressed a preference to operate the course as distance education. This means no physical classroom is assigned for this course. This also most likely means synchronous internet videoconferencing class sessions during the day(s) and time(s) when the course is scheduled to meet. However, other, more flexible modalities are possible, such as not using some of the scheduled class sessions to meet but instead supplementing with asynchronous distance education techniques. More details should be made available from the instructor via their syllabus or via other means as the start of the semester nears.

This is an LL.M class, and JD students may register, if space is available.

Prerequisites: Yes  Fed Income Tax

First Day Assignments:

Final Exam Schedule: Take Home exam      

This course will have:

Satisfies Senior Upper Level Writing Requirement: No

Experiential Course Type: No

Bar Course: No

DistanceEd ABA 306:

Pass-Fail Student Election: Available