Congress has created a comprehensive statutory system of criminal and civil sanctions to deter non-compliance with the filing and payment provisions of the Internal Revenue Code (“Code”). The goal of this statutory scheme is to protect the proper administration of the tax system and the revenue the system is intended to produce. The course will primarily explore the criminal sanctions, but will include examination of the civil fraud penalty and litigating the civil fraud penalty in the Tax Court. The course also will explore criminal tax investigations and case processing and the use of the federal grand jury to investigate criminal tax violations.

Prerequisites: Core Curriculum.

Spring 2008.