Using case studies, this course examines the strategic, jurisdictional and procedural problems and issues arising in the litigation of federal tax controversies before the U.S. Tax Court, District Court, Court of Claims and Bankruptcy Court. Practical problems including choice of forum, pleadings, discovery and tax trial practice will be considered. Criminal investigations and prosecutions will also be discussed. Student writing assignments will focus on drafting protests, pleadings and the briefing of tax issues.
Prerequisites: TAX 380, EST 200 and Core Curriculum; recommended TAX 190, UCL 200, ADV 400 (or new pre-trial ADV course)