Federal Tax Practice, Procedure and Research

Catalog description

Covers the history and organization of the Internal Revenue Service and the Federal judiciary as it relates to tax controversies. Emphasis is placed upon the examination and collection powers of the Internal Revenue Service and the legal and technical responsibilities imposed upon representatives. The deficiency and refund procedures are covered from the beginning of a tax controversy through its resolution by way of litigation. Included are the process by which returns are selected for examination, the conduct of examinations, the conduct of administrative conference proceeds, the Service’s investigatory and collection power. The sources and nature of the Federal tax law and its legislative, administrative and judicial explanations and interpretations are covered. Introduces students to the research tools available, their uses and limitations, and the processes by which ax professionals identify issues and apply controlling precedents in order to formulate research conclusions and professional recommendations.