Federal Tax Practice & Procedure
This course will provide students with an overview of practice before the Internal Revenue Service and procedures involved in tax controversies at the administrative level through civil court litigation. With a focus on practical skills, the course will prepare students for federal tax controversy practice and federal litigation. Through problems and practical exercises presented each week, the class will represent a fictional taxpayer from examination through litigation. Students will be given practice-based writing assignments, including responding to Information Document Requests, responding to a procedural motion, and moving for summary judgment. The course will culminate in mock oral arguments at the U.S. Court of Federal Claims before a judge of the court.