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Spring 2020
5254 Tax Controversy & Litigation - VASQUEZ JR. / VASQUEZ SR./ LOWY- 16580

Professor(s): Peter Lowy (ADJUNCT)
Juan Vasquez (ADJUNCT)
Juan Vasquez, Sr. (ADJUNCT)

Credits: 2

Course Areas: Taxation 

Time: ARRANGED    Location: 3  BLB

Course Outline: The Tax Controversy & Litigation course will cover the tax controversy process, starting with handling an IRS civil audit, administratively protesting before IRS Appeals, and representing a client in litigation before the United States Tax Court. Students will be instructed in taxpayer/client interview techniques and counseling, case evaluation, negotiation and settlement techniques, and trial techniques and strategies. At the Tax Court level students will learn: preparation and filing of the Tax Court Petition, Tax Court pre-trial procedures, presentation of a mock trial before Judge Vasquez from the Tax Court, and the post-trial briefing process.

The course will be taught in the simulation format that is used in Trial Advocacy courses, culminating in a mock trial before Judge Vasquez from the Tax Court.

This two-credit course brings U.S. Tax Court Judge Juan F. Vasquez to Houston to teach a course on Tax Controversy & Litigation. His fellow teacher will be Juan F. Vasquez, Jr., Shareholder of the law firm of Chamberlain, Hrdlicka, White, Williams & Martin and Chair of the ABA Tax Section's Committee on Court Procedure and Practice.

Course Syllabus: Syllabus

Course Notes: Quota= 36. This is an LL.M class, and JD students may register, if space is available. Juan Vasquez Jr. and Juan Vasquez Sr.   This course will meet on the following Fridays and Saturdays:
Friday January 24 - 1:30 to 4:30
Saturday January 25 - 9:00 to 12:30
Friday February 7 - 1:30 to 4:30
Saturday February 8 - 9:00 to 12:30
Friday February 21 - 1:30 to 4:30
Saturday February 22 - 9:00 to 12:30
Friday March 6 – 1:30 to 4:30
Saturday March 7 - 9:00 to 12:30

Prerequisites: Yes  Federal Income Tax.

First Day Assignments:

Final Exam Schedule: Projects      

This course will have:

Satisfies Senior Upper Level Writing Requirement: No

Experiential Course Type: simulation

Bar Course: No

DistanceEd ABA 306:

Pass-Fail Student Election:

Course Materials (1/7/2020 10:19:12 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 9780-7913-9269-0.

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: pl=/ecfrbrowse/Title26/26tab_02.tpl), 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. In addition, students will need access to the U.S. Tax Court Rules of Practice and Procedure. These are available online at