Professional Practice Program
PROFESSIONAL PRACTICE PROGRAM
Joint Training for the Approvals as
IRS SPECIAL ENROLLED AGENT
UNITED STATES TAX COURT PRACTITIONER
Practice before the Internal Revenue Service as an IRS Special Enrolled Agent and practice in the United States Tax Court as a United States Tax Court Practitioner recognized by the Court as "Tax Litigation Counsel"
Coordinated by James H. Chapman EA MPA MA
The Tax Law Institute's combined IRS tax practice and U.S. Tax Court litigation training program is for anyone who has an interest in tax accounting and tax law (restrictions may apply), and who has an aptitude for advocacy and legal research. It is a Professional Practice Program that combines the tax practice, including audit representation, (EA), with tax litigation (USTCP) training that leads to two designations approved by both the IRS and the U.S. Tax Court. The entire course of study may be completed in two years, if a person is truly motivated. It is almost entirely virtual, dial-in program popularized by returning military veterans with an interest in retooling.
The initial goal of the PPP is to expose persons to the rewarding career opportunities that are available in the U.S. Treasury Department Internal Revenue Service as an "IRS Special Enrolled Agent", and the benefits of advancing from enrolled agent to the professional designation, "United States Tax Court Practitioner" - a nonattorney, federally authorized tax practitioner (FATP) who is "Admitted to Practice, U.S. Tax Court".
The secondary goal of the program is to prepare the individual for a support staff and, eventually, a teaching role at both Tax Law Institute and/or with U.S. Tax Court Litigators.org. Further, at both TLI and USTCL, the tax practice areas are overseen by a case manager. To do these jobs, individuals must hold both the EA-USTCP credentials.
Qualifications for the PPP are determined by a Committee, composed of an IRS approved provider of continuing education in Federal Tax Law and U.S. Tax Court Trial Practice, a former U.S. Tax Court special trial judge, CPA members of the U.S. Tax Court Bar, IRS tax litigators and law professors - all members of the Teaching Faculty and/or Staff at the Tax Law Institute and U.S. Tax Court Litigators.org.
Prospective candidates are required to make known their interest in the program via transmission of an electronic Letter of Interest. If selected, individuals will then meet with the Program Director of the Tax Law Institute during an electronic interview.
Successful interviewees will then be prompted to submit a Written Statement of Goals & Objectives as defined during the electronic interview.
Selected candidates will then engage in an electronic and telephonic discussions with key members of the Committee. The goal being to determine the fitness and aptitude of the prospective candidate to pass the IRS Special Enrollment Examination and U.S. Tax Court Nonattorney Examination. A decision is transmitted within days thereafter.
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Becoming an IRS Special Enrolled Agent
If approved, the applicant enters a 4-6-month training program at the Tax Law Institute to learn the fundamentals of tax accountancy (tax return preparation and audit representation) and the Federal tax laws (Internal Revenue Code aka IRC).
At the conclusion of the program, successful applicants move in to a 4-6 month cooperative education endeavor (work-study), during which time the applicant is paired with an FATP who will help prepare the applicant to sit for all three (3) parts of the IRS Special Enrollment Examination aka SEE. The apprentice will also be engaged in tax preparation and audit representation work with a participating FATP.
Success in all three parts of the SEE qualifies the applicant, now a newly-approved EA, to begin the 8-12 month nonattorney bar review to prepare to sit for the U.S. Tax Court Nonattorney Examination. During this time, the Applicant/EA would continue in his/her engagement in tax preparation and audit representation with the participating FATP until such time when the Applicant/EA must sit for the nonattorney exam. The continuing experience would greatly enhance the EA prospects to pass the Substantive Tax Law section of the Tax Court exam, which is deemed to be the most challenging and problematic for non-attorney applicants.
Becoming a United States Tax Court Practitioner
The Tax Court Nonattorney Exam is administered once, every other year in Washington DC. If the EA receives a "pass letter" from the Tax Court then he/she will be subjected to a background check by the FBI. If an applicant is deemed "to be of good character" by the FBI, then the Tax Law Institute will "sponsor" (recommend) the successful bar applicant to the U.S. Tax Court Office of Admissions. The successful applicant is then sworn-in as a "Member of the Bar United States Tax Court" and issued a bar registration number. The bar registration number allows the newly-admitted USTCP to setup his/her practice as tax litigation counsel for prospective petitioner-taxpayers.
EA/USTCP Career Development
The newly-admitted EA-USTCPs then enter the 12-week "Apprenticeship Program", managed by the Tax Law Institute. This program includes courses in tax litigation training, trial documents preparation and legal writing for nonlawyers. When done, the newly admitted EA-USTCP begins tax practice as an EA and courtroom practice as a United States Tax Court Practitioner (aka "Counsel"). This will occur at the start of the Winter Session of the Tax Court. The newly admitted EA-USTCP will enjoy practice privileges that extend throughout the national jurisdiction, including U.S. territories or anyplace the U.S. Tax Court holds session. Whereas, a state-licensed attorney is restricted from practice across state lines by state bar rules of reciprocity, no USTCP can be prevented from accepting a case in Oregon or another case in Florida, just so long as he/she can appear for trial. See "USTCP Defined"
The newly admitted EA-USTCP is deemed to hold credentials that certify him/her as "IRS Enrolled Agent" aka simply as "EA" and "United States Tax Court Practitioner" aka "USTCP". Most newly-approved EA-USTCPs will be encouraged by us to opt to enter solo practice - usually the most lucrative option. (A select few will be offered program/case manager positions.) As a point of information, average industry-standard for annual incomes, in 2019, for an IRS Enrolled Agent engaged in tax return preparation and audit representation was $50,000-$120,000, or more. Annual legal fees collected, for an EA who is also a United States Tax Court Practitioner, and engaged in small ("s-") case practice (administrative resolutions) and/or regular case practice (litigation), averages, $75,000-$150,000, or more. All figures are affected by locality, full- or part-time service, and practice concentrations and specializations.
The Judicial Merit Award recipient (top performers in each profession) will be considered first, for permanent placement as adjunct instructor at the Tax Law Institute and as support staff at U.S. Tax Court Litigators.org. But some graduates of the Program may look to placement at top-tier law and accounting firms, engaged in Federal Tax Practice throughout the national jurisdiction. Many such placements are high-compensation jobs, often starting in salary ranges of $80,000 to $150,000 annually.
Nevertheless, the newly-admitted EA-USTCP should be in very high demand as a tax litigation specialist as he/she knows both the accounting and law side of a tax case. Some might find that there calling is toward acting as an "expert witness" who can earn fees from $1500 up to $25,000 for written or oral testimony in all types of Federal and State tax court cases, especially among law and accounting firms as well as from local attorneys in solo practice.
The current cost for the Professional Practice Program is approximately $29,500 - $33,500, and includes all books and print materials used in the program, but does not include accommodations and meals where applicable. Payment plans are available.
The entire program is taught mostly in a virtual environment, usually for a total of 3 hours of class time each week.
The Letter of Interest, and any other supporting documents, as requested, should be sent to the following person's electronic address: