Tax Practice and Procedure

Spring 2010
LAW 601
Credits: 2

Instructor: Jonathan Mishkin

An in depth view of the procedural issues facing tax practitioners. Emphasizes the legal principles underlying the federal, and to a limited extent Oregon, tax procedural issues and their application in tax related practice. Course covers the whole range of a taxpayers relationship with the Internal Revenue Service from filing returns through audits, and the handling of any resulting controversy. Included will be requests for rulings and technical advice memoranda, periods of limitation and their mitigations, IRS deficiency procedures and conference procedures, transferee liability and the assertion of, and defense against, civil tax penalties