The course examines the administration and enforcement of the federal income tax laws, including preparation and filing of returns; withholding and information reporting; administrative determination of liability, penalties and interest; audits; summonses; deficiencies and assessments; conference and settlement; limitation periods and their mitigation; transferee liability; collections and tax liens; burden of proof; choice of forum; and other features of civil tax litigation.

This upper-level substantive course examines the administration and enforcement of the federal tax laws.

Open to Tax LL.M. students only.

2 Credits