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Fall 2017
5292 Tax Procedure - VASQUEZ, JR.- 12558

Professor(s): Juan Vasquez (ADJUNCT)

Credits: 2

Course Areas: Taxation 

Time: 5:30p-7:30p  TH  Location: 115  BLB

Course Outline: This class covers the procedural aspects of dealing with the Internal Revenue Service, the
agency that administers the federal tax system. The focus is from the private practitioner's
perspective in assisting clients navigate the daunting administrative requirements. The class offers
the following principal subjects:
• Administrative Organization of the IRS.
• The Regulatory Process -- IRS Pronouncements such as Regulations, Revenue Rulings,
Technical Advice Memoranda and Private Letter Rulings
• IRS Audits, including use of IRS Administrative Summonses and Statutes of Limitations
Penalties (Civil and Fraud) and Interest
• IRS Administrative Appeals
• Civil Tax Litigation with the IRS -- Tax Court, District Court, Court of Federal Claims,
Courts of Appeals and United States Supreme Court.
• Collections, including IRS liens and levies
• Federal Tax Crimes, Methods of Proof and Investigative Techniques
• Ethics of Practice in the Tax Procedure Context

Course Syllabus: Syllabus

Course Notes: This is an LL.M class, and JD students may register, if space is available.   

Prerequisites: Yes  Fed Income Tax

First Day Assignments:

Final Exam Schedule: 12/7 6 - 8PM  213 BLB    

This course will have:

Satisfies Skills Course Requirement: No
Satisfies Senior Upper Level Writing Requirement: No

Experiential Course Type:

Bar Course: No

Course Materials (8/11/2017 11:00:06 AM)

Book(s) Required

The course is taught from materials prepared by the instructors and readings from Michael I. Saltzman, IRS Practice and Procedure, Warren Gorham & Lamont (Rev. Second Ed., Student Edition) and latest supplement. This is a revised 2nd edition with latest supplement. ISBN is 978-0-7913-8942-3.

Students will need access to the Internal Revenue Code (26 U.S.C. 1 et seq.) and Treasury Regulations promulgated thereunder (26 CFR 1 et seq.). These are available online (Code:;Regs:;Regs:
), but students should have copies of the relevant provisions in class and thus it may be best simply to purchase one of the compilations available in the bookstore.