Tax Practice and Procedure Seminar
Section 1, Spring 23
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This course is intended for 2L and 3L students who intend to pursue a career in tax law, whether in tax planning or in tax controversy work. The course will focus on the progression of a tax dispute from the planning stages through to litigation. Students will consider how to properly and accurately characterize a transaction on a tax return, how to defend the transaction at the administrative stage in an IRS audit, and, finally, how to choose a forum to litigate the tax treatment of the transaction. We will also consider certain ethical issues, IRS Circular 230 and other issues that may arise in the course of a taxpayer's dealings with the IRS and the courts.
Final Type (if any): None
Written Work Product
Written Work Product: The final paper is due via EXPO by noon (EST) on the last day of the examination period. Alternatively, a student wishing to satisfy the Upper-Level Writing Requirement may opt to do so by permission of the instructor by submitting a substantial research paper in lieu of the brief-writing assignment. Those students wishing to take this option must timely submit the required completed form to SRO. The deadline to submit the form to SRO is posted in the Enrollment Deadlines section of LawWeb. Retroactive exceptions will not be granted.
Other Course Details
Prerequisites: None Concurrencies: None
Mutually Exclusive With: None
Laptops Allowed: Yes
First Day Attendance Required: No
Course Resources: To be announced.
*Satisfies Writing Requirement: No
**Credits For Prof. Skills Requirement: No
Satisfies Professional Ethics: No
*If “Yes,” then students are required to submit a substantial research paper in this course, which means students do not need to submit any form to SRO for this paper to meet their upper-level writing requirement. If “No,” then students must submit a “special request” e-form to SRO (available via LawWeb) no later than five weeks after the start of the term for a paper in this class to be counted toward the upper-level writing requirement.
**Yes indicates course credits count towards UVA Law’s Prof. Skills graduation requirement, not necessarily a skills requirements for any particular state bar.
Cross Listed: No
Cross-Listed Course Mnemonic:
Concentrations: Litigation and Procedure, Tax Law
Public Syllabus Link: None
Evaluation Portal Via LawWeb Opens: Friday, April 21, 12:01 AM
Evaluation Portal Via LawWeb Closes: Sunday, April 30, 11:59 PM