This casebook teaches the mechanics of tax procedure, while stimulating students to think about the broader issues that underlie its structural framework. Tax Controversies: Practice and Procedure begins with an overview of civil tax procedure and an in-depth discussion of the federal tax gap and the many approaches to closing it. Several of the next chapters focus on stages in the chronology of a typical tax controversy, from examination through eventual litigation. Two chapters focus on tax research and representing tax clients, and another chapter addresses ethics issues in tax cases. An underlying theme—the extent to which the current procedural rules encourage or discourage voluntary compliance with the federal tax system—runs throughout the book.
• Suitable for J.D. or LL.M. students, or for use in a tax clinic.
• Each casebook chapter includes theory questions and a set of fact-based problems to encourage strategic thinking. Several chapters include optional drafting problems.
• Teacher's Manual provides detailed answers to the problem sets, suggests approaches to the material, and highlights topics more suitable for an advanced course.
• This edition is thoroughly updated to reflect developments in the law since the previous edition.
• Separate Documents Volume, Tax Controversies: Statutes, Regulations, and Other Materials, is also available.