Tax Litigation


TAX LITIGATION
Apprenticeship

Simulated trial practice in the
Acting United States Tax Court Virtual Forum

Certificate Program

to qualify to serve as

"TAX LITIGATION COUNSEL
FOR THE PETITIONER"

&

"PRE-TRIAL TAX LITIGATION
SUPPORT SPECIALIST"

image-858256-native_american_justice-45c48.jpg

Acting Presiding judge

Formerly Special Trial Judge of the U.S. Tax Court Judiciary and currently the Distinguished Judicial Speaker in Residence at the Tax Law Institute

&

Acting IRS counsel

Formerly Judicial Clerk of the U.S. Tax Court, IRS Litigator in the Office of Chief Counsel and currently Distinguished Author in Residence at the Tax Law Institute

United States Tax Court Calendar Call with Special Trial Judge Lewis Carluzzo presiding...
Simiulated Calendar Call
United States Tax Court

YouTube Video Courtesy of U.S. Tax Court

This course is for United States Tax Court Practioner candidates, FATPs preparing to assist in pre-trial tax litigation, and designated United States Tax Court Practitioners who have limited trial practice experience in U.S. Tax Court

Acting Clerk of the Court

IRS Approved Provider of Continuing Professional Education and currently Program Director at the Tax Law Institute

Register +1.800.513.1598

Session 1

Jan. 9, 2021-      May 1, 2021-
Jan. 30, 2021      May 22, 2021

Session 2

Feb. 6, 2021-      June 5, 2021-
Feb. 27, 2021      June 26, 2021

Session 3

Mar. 6, 2021-      July 10, 2021-
Mar. 27, 2021     July 31, 2021

Treatise Required

  • 1. Selection of Tax Litigation Forum
  • 2. US Tax Court Jurisdiction and Structure
  • 3. Statutory Notice of Deficiency
  • 4. Petition for Redetermination
    • Jurisdictional and Procedural Filing Requirements
    • Petitioners
  •  5. Pleadings and Motions
    • Basic Rules
    • Types and Content of Specific Pleadings
    • Amended and Supplemental Pleadings
    • Motions
  •   6. Stipulations for Trial and Discovery Procedures
    • Stipulations for Trial
    • Discovery Procedures
  •   7. Pretrial Procedures
    • General Pretrial Practice
    • Pretrial Procedural and Evidentiary Motions
    • Settlement Procedures
    • Setting the Case for Trial
  • 8. Trial Proceedings
  • 9. Litigation of Partnership Items
  • 10. Special Proceedings
    • Small Tax Cases
    • Disclosures Actions
    • Collateral and Supplemental Proceedings
    • Other Proceedings
  • 11. Post-Trial Proceedings
    • Opinions, Reports, and Decisions
    • Post-Trial Motions
    • Appellate Review in Court of Appeals
    • Review by Supreme Court
    • Rules of Finality
    • 12. Refund Claims
      • Proper Party to File a Claim for Refund
      • Administrative Requirement as to Claim for Refund
    •  13. Periods of Limitations for Filing Claims for Refund
    •  14. Administrative Procedures on Filing Refund Claim
    •  15. Jurisdictional Prerequisites and Pretrial Considerations
      • Jurisdictional Requirements
      • Pretrial Considerations
    •  16. Special Refund Litigation Considerations
    •  17. Commencement of Tax Refund Suit and Initial Pleadings
    •  18. Pretrial Procedure
    •  19. Post-Trial Procedures
    •  20. Other District Court Civil Tax Litigation
      • Suits Commenced by the United States
      • Suits Commenced by Taxpayers and Third Parties
    •  21. Actions for Declaratory Judgment
    •  22. Res Judicata and Collateral Estoppel in Civil Tax
    •  23. Recovery of Attorney's Fees and Extraordinary Costs

    Fee $4995

    Offered concurrently with "Trial Documents" & "Legal Writing for USTCPs"
    Awards 12 CPE/CE Credits

    26 U.S. Code Title 26 Internal Revenue Code Courtesy of Cornell Law School Legal Information Institute


    Register +1.800.513.1598




    Extended Office Hours
    Mon - Sat: 09:00 AM - 07:00 PM

    Please contact us to determine your qualifications to sit for this course.