LAW 2843 - Federal Tax Procedure
This course examines the basic rules of federal tax procedure, focusing primarily on civil tax matters. Topics covered include the sources of federal tax procedure; IRS organization, operation and administration; ruling requests and determination letters; retroactive and prospective changes in IRS interpretations; the doctrine of estoppel, consistency and equality as applied to IRS actions; audit and summons powers of the IRS; deficiencies, interest and penalties; refund claims; statute of limitations, waivers and the mitigation provisions; appeals and settlement procedures within the IRS; forums available for judicial review of IRS determinations; assessment and collection procedure; injunctions and suits to restrain assessment and collection; disclosure obligations imposed by the IRS and the Freedom of Information Act; confidentiality of tax returns; and criminal investigations.
Prerequisites & Notes
Federal Income Taxation of Individuals.
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