Fall 2023
Professor(s):
Juan Vasquez, Jr. (ADJUNCT)
Credits: 2
Course Areas: Taxation
Time: 5:30p-7:30p T Location: 311
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
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.
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 Take home
This course will have:
Exam:
Paper:
Satisfies Senior Upper Level Writing Requirement: No
Experiential Course Type: No
Bar Course: No
DistanceEd ABA: No
Pass-Fail Student Election: Available
Course Materials
Book(s) Required
The course is taught from materials prepared by the instructors and readings from Michael I. Saltzman & Les Book, IRS Practice and Procedure, Thomson Reuters (Rev. Second Ed., Student Edition) and latest supplement. This is a revised 2nd edition with latest supplement. Book & Supplement Combo ISBN 978-1-5083-1130-0 or Study Problems ISBN 978-0-7913-5535-0.
Students will need access to the Internal Revenue Code (26 U.S.C. 1 et seq.) and Treasury Regulations promulgated thereunder (26 CFR 1 et seq.). These are available online (Code: http://www.access.gpo.gov/uscode/uscmain.html; Regs: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?sid=223533d4a55442ad0e5ac135507b8906&c=ecfr&tpl=/ecfrbrowse/Title26/26tab_02.tpl), but students should have copies of the relevant provisions in class and thus it may be best simply to purchase one of the compilations available in the bookstore.
Optional reading material: Vasquez & Head, From the Texas Cotton Fields to the United States Tax Court: The Life Journey of Juan F. Vasquez, American Bar Association Tax Section (2020)
