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Spring 2023

5254 Tax Controversy & Litigation - VASQUEZ JR. / VASQUEZ SR./ LOWY- 12810

Professor(s): Peter Lowy (ADJUNCT)
Juan Vasquez, Jr. (ADJUNCT)
Juan Vasquez, Sr. (ADJUNCT)

Credits: 2

Course Areas: Taxation 

Time: ARRANGED    Location: 211 

Course Outline: The Tax Controversy & Litigation course will cover the tax controversy process, starting with handling an IRS civil audit, administratively protesting before IRS Appeals, and representing a client in litigation before the United States Tax Court. Students will be instructed in taxpayer/client interview techniques and counseling, case evaluation, negotiation and settlement techniques, and trial techniques and strategies. At the Tax Court level students will learn: preparation and filing of the Tax Court Petition, Tax Court pre-trial procedures, presentation of a mock trial before Judge Vasquez from the Tax Court, and the post-trial briefing process.

The course will be taught in the simulation format that is used in Trial Advocacy courses, culminating in a mock trial before Judge Vasquez from the Tax Court.

This two-credit course brings U.S. Tax Court Judge Juan F. Vasquez to Houston to teach a course on Tax Controversy & Litigation. His fellow teacher will be Juan F. Vasquez, Jr., Shareholder of the law firm of Chamberlain, Hrdlicka, White, Williams & Martin and Chair of the ABA Tax Section's Committee on Court Procedure and Practice.

Course Syllabus:

Course Notes: (Face-to-Face)  The UH registration system instruction mode for this course is listed in parenthesis. After student registration opens, there may be instruction mode changes to this course up through two weeks before the first day of classes for the term, but notice of such changes will be sent to then-registered students. For this instruction mode, instructors and students are expected to normally be physically present in the classroom. If the course has a final examination, it will be in a classroom requiring your physical presence. Other assessment, such as a mid-term exam, may also be in a classroom. Whether this instructor will offer “remote presence” (starting a zoom meeting from the podium computer to enable student remote access on an occasional basis) for part or all of the semester is not known, but students should not rely on an expectation that remote presence will be available.

Quota= 25.

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

This course will meet on the following Fridays and Saturdays:

Friday January 20, 2023 1:30pm to 4:30pm
Saturday January 21, 2023 9:00am to 12:30pm
Friday January 27, 2023 1:30pm to 4:30pm
Saturday January 28, 2023 9:00am to 12:30pm
Friday February 17, 2023 1:30pm to 4:30pm
Saturday February 18, 2023 9:00am to 12:30pm
Friday March 3, 2023 1:30pm to 4:30pm
Saturday March 4, 2023 9:00am to 12:30pm

Prerequisites: Yes  Federal Income Tax.

First Day Assignments:

Final Exam Schedule:    

This course will have:

Satisfies Senior Upper Level Writing Requirement: No

Experiential Course Type: simulation

Bar Course: No

DistanceEd ABA: No

Pass-Fail Student Election: Conditional Availability (not for required credits)