Fall 2025
Professor(s):
Juan Vasquez, Jr. (ADJUNCT)
Credits: 2
Course Areas: Taxation
Time: 6:00p-8:00p T Location: 260
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. 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:
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
Course Materials: The course is taught from materials prepared by the instructors and readings from Michael I. Saltzman & Les Book, IRS Practice and Procedure, Thomas Reuters (Rev. 2 Second Ed., Student Edition) and latest supplement. This is a revised 2nd edition with latest supplement. Book & Supplement Combo ISBN 9781508311300 or Study Problems ISBN 978-0-7913-5535-0.
