Professional Practice and Tax Procedure
This course provides a working knowledge of federal tax procedure that is essential for all tax practitioners, including those who concentrate tax planning, tax compliance, or tax controversy. You will be introduced to the players in the tax system and the organizational structure, personnel, and authority of the Internal Revenue Service. We will study the published guidance process, tax return filing requirements, assessments, tax audits, summonses, deficiencies, claims for refund, statute of limitation, penalties, interest, and the administrative dispute resolution process.
Although we focus on tax practice at the administrative level, we will introduce you to the options for litigating tax disputes which may impact the client’s decision making. The course also presents common ethical issues confronting today’s tax practitioners starting with an acknowledgement that while there is a duty of competence, loyalty, and confidentiality owed to the client there is also a compelling professional duty owed to “the tax system.” Our guiding principles will be derived collectively from Treasury Department Circular No. 230 and the standard of practice found in the ABA Model Rules and the AICPA Standards of Tax Practice.