The John F. Dean Apprenticeship

... to ensure that everyone gets the attention they deserve 

United States Tax Court Practitioner Defined

A United States Tax Court Practitioner aka Tax Litigation Counsel is an United States Tax Court-approved tax professional and legal strategist, who has received litigation training and been examined by and admitted to practice in the United States Tax Court. They represent taxpayers - individuals, partnerships, corporations, estates and trusts - during legal proceedings held exclusively in U.S. Tax Court. Because of their highly specialized tax accounting skills, litigation training, and stringent IRS approval and practice requirements, USTCPs are often chosen by tax clients over tax attorneys to handle deficiency matters, civil fraud offenses and other complex tax controversies that migrate into U.S. Tax Court. 

The John F. Dean Apprenticeship for Litigation & U.S. Tax Court Trial Practice

• Orientation - January 10, 2026

• Organized by Michael Jerome Stuart, Professor Emeritus at the Tax Law Institute and U.S. Treasury Department Internal Revenue Service-Approved Provider of Continuing Professional Education. 

• Developed, advanced and first-presented by Judge John F. Dean, Ret., formerly of the U.S. Tax Court Judiciary, and upon his retirement from the bench, Distinguished Judicial Speaker at the Tax Law Institute for six years, and Joni D. Larson, eminent legal author and Distinguished Scholar and Professor of Law. 

• The John F. Dean Apprenticeship is the nation's top (#1) attorney- and non-attorney training program for Tax Bar Preparation and U.S. Tax Court Litigation and Trial Practice. The combined program can be completed in just 18-22 months of remote study and in-person and remote pro bono practice - usually in conjunction with the U.S. Tax Court 2-Year Testing Cycles for the Tax Bar Examinations.  

• Traditional law school apprenticeships take a minimum of four (4) years to complete in any of the 4 states where an individual is 'to read' the law under the supervision of a seasoned licensed attorney or judge. Afterwards, an individual is allowed to sit for the respective state bar examination. Whereas individuals who pass the Tax Court bar exam and then hang out their shingle to begin practice as a legal representative are in fact going into a courtroom with no formal legal training. 

• The John F. Dean Apprenticeship for Litigation and U.S. Tax Court Trial Practice is a rolling admissions program that speaks to the mission of the United States Tax Court, a national forum for the expeditious resolution of disputes between taxpayers and the Internal Revenue Service. The objective of the apprenticeship is to convey to future federal tax litigators that the Court is committed to providing taxpayers, most of whom are self-represented, with a reasonable opportunity to appear before the Court, with as little inconvenience and expense as is practicable. And that the Court is also committed to providing an accessible judicial forum with simplified procedures for disputes involving $50,000 or less. Our objective is to provide well-trained, non-attorney legal practitioners to assist them as well as moderate- and high-liability taxpayers.

• We recognize that sometimes taxpayers choose not to go-it-alone and often prefer to be represented. And many believe they can neither afford nor do they want to retain a licensed tax attorney, who may or may not be the appropriate talent to address their concerns. So, they turn to their  CPA or IRS enrolled agent who prepared their tax returns and discover that these individuals are not authorized to represent their tax deficiency or other interests before the Tax Court. Enter the United States Tax Court Practitioner.

• We also wish to consider that although many of the discussions focus on the individual taxpayers and small businesses, we cannot overlook the fact that, as indicated above, the United States Tax Court also is the legal forum where large corporate and partnership tax controversies are resolved. Subsequently, high-liability tax deficiencies also are docketed on the Tax Court calendar and cases not settled are tried. Therefore, our Apprenticeships speak to both categories of taxpayers - low-to-moderate income as well as high income that gives rise to high-liability tax litigation associated with big business. Indeed, United States Tax Court Practitioners have a role at the table and are increasingly becoming associated with the top-tier and white shoe law firms that are engaged in these types of federal tax litigation practices, e.g. TLi Litigation Services Group.

• The United States Tax Court Practitioner should not be mistaken for the cheap alternative to hiring a tax attorney. If you haven't yet read the 'The Best Kept Secret' then do so now. Their unique skills in tax accounting, auditing, tax law and litigation and trial practice make them a rare find whose fees fall within range of $275-$650 per hour. And then, their are the Specialists who can earn up to $1200 an hour.

• Our Apprenticeship | Federal Tax Litigation and Trial Practice Program is designed for both the socially-conscious and the ambitious tax professional. There is a great opportunity to reap substantial fees and also perform a valuable public service. Either/or, it depends entirely on you as to  what uses you make of the training we provide. 

Preliminary Program Structure

• The courtroom-student litigation and trial practice component of the apprenticeship occurs during the Fall, Winter and Spring Trial Sessions of the U.S. Tax Court. (Classes also convene during the summer months as well although the Court is recessed.) Each Apprentice is assigned to assist at the free tax clinic we support. And one or two opt to intern with the TLI Litigation Services Group.They go to work under the supervision of a USTCP soon after they begin the program. The Apprentice gets a real-world experience surrounding their studies at TLI. It is an exciting activity and offers early insight into what a career as a USTCP aka Tax Litigation Counsel is actually like. The Apprentice gets to work remotely and in-person with both low-income (pro bono) and non-qualified clients who have docketed cases in U.S. Tax Court. Look to the green sheets at https://www.ustaxcourt.gov/trial_sessions.html for the schedule of calendar call dates and in-person pro bono proceedings when the Tax Court convenes in various cities during 2026.

In-Person U.S. Tax Court Pro Bono Practice

• Our in-person Honolulu U.S. Tax Court  component begins tentatively on Monday, June 1, 2026 and concludes on Thursday, June 4, 2026. Participating Apprentices depart from their respective local airports enroute to Honolulu, Hawai'i. The Court is tentatively scheduled to  convene on Wednesday, June 3, 2026. Pro bono representatives should arrive at the Court in time for the 9:30 a.m. HT Calendar Call. They will assist low-income clients who appear to answer their calendar call and other unrepresented taxpayers who qualify under IRS guidelines for free services. The expenses for airfare and hotel accommodations are covered by the Tax Law Institute. Apprentices are responsible for the provision of their own meals.

Who Should Apply?

• The Apprenticeship is best suited for federally authorized tax practitioners (CPAs and EAs) who want to pass the 2027 Tax Bar Examination and guarantee themselves a high-paying career in Federal Tax Litigation. First-time test-takers, repeat test-takers and newly-admitted USTCPs are ideal candidates. Nevertheless, other tax professioinals may also apply.

Nature of the Apprenticeship

• The Apprenticeship takes on the judicial approach to provide guidance for future tax court litigators as proposed by the retired Tax Court judge, who shaped our litigation and trial practice program at its inception. 

• It begins with a comprehensive review of Federal Tax Procedure, Internal Revenue Code (IRC), Tax Evidence, U.S. Tax Court Rules of Practice and Procedure, Case Law and Legal Ethics. 

• Next, we address the first of the unwritten rules of practice - getting paid and not getting sued! So, we consider, in detail, how to Manage Client Expectations and Structure Fees, including advice about the do's and don't when writing the retainer agreement or engagement letter. Then we move on to discuss Malpractice Insurance and Legal Liability of United States Tax Court Practitioners and the ethical rules of conduct, including the pitfalls of court-imposed sanctions.

• Next, we breakout the Statutory Notice of Deficiency aka NOD and discuss what constitutes due diligence. 

• We then take a close look at the legislative explanations for Tax Court Jurisdiction over various actions and practice writing the Petition (initial pleading).

• We then enter into a discussion about the IRS Independent Office of Appeals, but from a perspective unfamiliar to the CPA and EA bar candidate - that of a tax litigator negotiating with a government attorney. 

• Next, we turn our attention to informal discovery and enact a mock Branerton Conference, after which we will engage in various negotiation tactics to attempt a Settlement (over trial) and then write the initial Stipulation. 

• Afterwards, we start an in-depth examination of the use and preparation of Trial Documents that get you the information you need to prosecute your case. This process is known as Formal Discovery  (Pre-Trial Motions, Interrogatories and Depositions). Formal Discovery is minimalized in U.S. Tax Court and the extent of which is at the discretion of the presiding judge.

• We will then start to perfect skill sets to prepare lawyerly Legal Writing and Documents Preparation, and Case Related Forms, formatted with a goal to create professionally-styled pre-trial submissions. Please remember that Tax Court proceedings are document-driven. Preparation and research take the litigator to the half-way point. The trial serves to present the evidentiary information and have it admitted into the record. The judge will then reserve his decision based upon the preponderance of the evidence standard.

• Finally, we will get to the most exciting segment of the course that begins with analytical discussions of Litigation Strategies for U.S. Tax Court. Here, we develop sound written and oral legal arguments based upon selected case scenarios which the USTCP can employ before, at and after Trial and Case  Presentation. Next, we will review various Orders and Opinions issued by the Court to learn how judges reason. Lastly, we will show the Apprentice how to Search the database using the Dawson system to find current and past cases and opinions. We end these discussions after listening to a top tax litigator, who is invited to describe his/her experiences with the Tax Court. 

• Lastly, we will address Post-Trial Matters, i.e. Post-Trial Briefs, Opinions, Decisions, Post-Trial Motions and Appeals. Be aware that in U.S. Tax Court a case can turn on a well-written and persuasive Post-Trial Brief. This is where the evidence admitted into the record at trial is re-presented and summarized, along with the arguments, so the judge can make a final ruling. It is the last opportunity for the litigator to influence the Court through the use of post-trial motions.

Mock Hearings & Trials Explained

• Under the supervision of the Teaching Faculty, a mock Tax Court judge and a seasoned tax litigator, select precedential cases that are re-enacted in hearing and trial format. Hearings arise when one of the parties submits a motion where counsel or counselor (government attorney) needs to be heard. The Apprentice will take on the persona of tax litigation counsel, government attorney, IRS representative, witness and taxpayer during a Mock Trial Program. We will then walk-through the process of how to obtain transcripts of these and other court  proceedings from the Court. The apprentice gets an opportunity to apply what they learn and to perfect their skills - before, during and after they are assigned to assist tax clinic staff and taxpayer-clients, under the supervision of participating USTCPs engaged with the free tax clinic's U.S. Tax Court Clinical, Student Practice and Calendar Call Program. 

Mock U.S. Tax Court Trial | Zoomgov.com

• Please open the following link to view mock U.S. Tax Court Trial | Speaker View https://www.zoomgov.com/rec/play/vJ15Iu37rDI3SNWRsASDVqQsW9W4f6qshykW_6ENmUy8BXgDNVT3Y-cUNOtJy1Csd5uM_q_l1h92qJyk

• Please open the following link to vew mock U.S. Tax Court Trial  |  Gallery View https://www.zoomgov.com/rec/play/vZV_c-us-DM3E9zGuQSDU6UtW466fK-s1SJPr6AMyUrmWiYBZ1unZ-RAJhhPJ3q-2_gTftw65Yr0Lg

Case Decisions: U.S. Tax Court Reports

• These Reports contain the official, formally published decisions of the U.S. Tax Court. These "regular" decisions are issued in cases involving novel or particularly important legal issues and carry precedential weight. 

Specialization Courses

1. Civil Tax Fraud Defense 
2. Partnership and Corporate Tax
3. Small Business Taxation
4. Nonprofit Organizational Development, Management & Finance
5. Entertainment and Sports Management Taxation
6. Taxation of Certain International Transactions 

Fees

• The total costs for the combined Apprenticeship and Tax Bar Prep is $61,012.00
• The Apprenticeship fee is $29,995 (less 25% deposit of $7,498.75) leaving a remaining balance due of $22,496.25 + 10% Surcharge on this remaining balance and on all other unpaid fees
• The Tax Bar Prep fee is $9,570
• The Specialization Course fee is $4.995 (taught post-2027 Tax Bar Exam)
• The Self-Instructive Tax Law Library access fee is $4,995
• The Textbook cost is $1717 (fee contributed to Free Tax Clinic)
• The Litigation Services Internship fee is $2,500 (optional)
• The Free Clinic Contribution remote pro bono fee is $1,000
• The Free Clinic Contribution in-person pro bono fee is $1,000
• The registration fee for the Apprenticeship is $250
• The registration fee for the Tax Bar Prep is $125

►Financing: @ 10% surcharge

Caveat

• Please note that the program has strict admission criteria that must be met. Participation in the Tax Bar Prep does not necessarily lend itself to Apprenticeship admission. TLI reserves the right to deny admission to the Apprenticeship, where academic performance of the applicant indicates poor prospects for future litigation and trial practice success. Similarly, a reserved right exist to dismiss from the Apprenticeship  Program any person whom the Teaching Faculty deems is out of compliance with the tenets of the training goals and objectives.

Teaching Faculty

Louis B. Carpenter III   CPA CFP USTCP

• Assistant Professor Emeritus of Federal Tax Practice and Chief Tax Counsel Emeritus
• Chief Tax Litigation Counsel Emeritus, Hawai'i Federal Tax Clinic on O'ahu
• Registered Coordinator, U.S. Tax Court Clinical, Student Practice and Calendar Call Program
• Pro Bono Advisor, Tax Litigation Clinic at the Tax Law Institute a Washington DC
• Member of the Board, Hawai'i  Federal Tax Clinic

 James H. Chapman   EA MPA MA

• Associate Professor Emeritus of Federal Tax Research & Practice
• Chair of the Board of Directors, Hawai'i Federal Tax Clinic on O'ahu

Daniel Ng   J.D. LL.M.

• 2025-2027 Litigation & Case Law Specialist and Advisor
• Interim Director, Hawai'i Federal Tax Clinic on O'ahu
• Member of the Board, Hawai'i Federal Tax Clinic

Michael Jerome Stuart   J.D. MPA

• Professor Emeritus
• The John F. Dean Professor of Federal Tax Litigation & U.S. Tax Court Trial Practice at the Tax Law Institute at Washington DC
• Director, Tax Law Institute at Washington DC
• President, Hawai'i Federal Tax Clinic on O'ahu
• Approved Provider of Continuing Education, IRS Office of Professional Responsibility

Jeffrey Thompson   E.A. MBA  M.A.  USTCP

• Faculty Intern and Lecturer  |  2024-2026
• Tax Litigation Counsel
• Acting Clinic Director | Hawai'i Federal Tax Clinic on O'ahu
• Assistant Coordinator | U.S. Tax Court Clinical, Student Practice and Calendar Call Program
• Team Leader | Pro Bono Program 

Guest lecturers are invited to speak as well. 

Below is the Apprenticeship program schedule for the 2026-2027 Testing Cycle

Course Schedule |  U.S. Tax Court Sessions Calendar: 2026-2027

• Winter 2026 | Session 1 | Case Preparation & Management
• Classes meet every Saturday | 90-120 minutes | Reading assignments | Discussions
• Pro Bono Practice in Honolulu U.S. Tax Court

Break

• Spring 2026 | Session 2 | Mock Trials: Litigation Strategies in U.S. Tax Court
• Class meets every Saturday | 90-120 minutes | Reading assignments | Mock Trial Program | Individual instruction given by expert trial practitioners
• Pro Bono Practice in Honolulu Tax Court

Break

• Fall 2026 | Session 3 | Mock Trial Practice in U.S. Tax Court.  
• Classes meet every Saturday | 90-120 minutes | Reading assignments.  In accordance with remote calendar of U.S. Tax Court | Documents preparation | Trial Practice | Oral Argument | Under oversight of participating counsels.
• Pro Bono Practice in Honolulu U.S. Tax Court

            Taught in conjunction with ... 

Tax Bar Prep | Course Listing | Comprehensive Review

• Orientation to the Tax Bar Examination
• Federal Rules of Evidence as Applied  in Tax Court
• Federal Tax Procedure
• IRC
• U.S. Tax Court Rules of Practice and Procedure
• Case Law
• Legal Ethics | Model Rules of Professional Conduct

Break

Comprehensive Tax Bar Review

• Q &A : Selected questions from the 2021, 2023 and 2025 Tax Bar Exams
• Review of selected sections of  Federal Tax Procedure
• Review of selected sections of the IRC
• Review of Federal TaxationReview of Tax Evidence
• Review of Legal Ethics
• Review of U.S. Tax Court Practice and Procedure
• Review of Case Law

All remote classes audio-video conferencing convene in the TLI Virtual Conference Rooms and break every 50 minutes.

*This guide provides resources about the Court's Zoomgov remote proceedings.  Click/Tap here.

Course Discussions | Textbook Readings

LITIGATING IN TAX COURT

1. The Decision to Litigate

     a.  Performing Due Diligence: The Statutory Notice of Deficiency

     b.  Taxpayers' options

     c.  Exhausting All Remedies with IRS

2. Eligibility to Represent a Petitioner

     a. Admission in Good Standing

     b. Skills and Training

3. Managing Client Expectations

     a. Fee Structuring

     b. Expense Predictions

     c. Client and Practitioner Expectations

Trial Documents

          Statutory Notice of Deficiency

          Application for Admission to Practice (Attorneys)

PART 1

TAX COURT JURISDICTION

4. Determining Tax Court Jurisdiction Over Actions for Declaratory Relief

     a. Section 7428 Actions

     b. Section 7476 Actions

     c. Section 7477 Actions

     d. Section 7478 Actions

     e. Section 7479 Actions

     f. Section 6234 Actions

5. Determining Tax Court Jurisdiction Over Other Actions

     a. Section 6015 Actions

     b. Section 7436 Actions

     c. Tax Court Rule 240

     d. Section 6512(b) Actions

     e. Other Actions

PART 2

6. PLEADINGS

General Forms of All Pleadings

     a. Allowable Pleadings and Privacy Protections

     b. Purpose of pleadings

     c. Caption and signature

     d. Form and style

     e. Service of pleadings

7. Petition

     a. Time for filing

     b. How to file

     c. Filing fees

     d. Content of petition

8. Answer

     a. Time for filing

     b. Content of answer

9. Reply

     a. When a reply is required

     b. Content of a reply and time for filing

10. Small Case Procedures

     a. Purpose

     b. Pleadings

11. Amended and Supplemental Pleadings

     a. Time for amendments

     b. Amending pleadings to conform to evidence presented at trial

     c.  Supplemental pleadings

12. Joinder of Issues

     a. Case is "At Issue"

Trial Documents

          Certificate of Service

          Motion to Waive Filing Fee

          Designation of Place of Trial

          Sample Petitions

          Sample Answer in response to Comprehensive Petition

          S Case Procedure

          Deficiency Petition

          Request for Designation of Place of Trial

          SFR Petition

          Brief for Petitioner

          Opening Brief of Respondent

         Reply Brief for Petitioner

         T.C. Memo 2006-04

         Sample Ownership Disclosure Statement

PART 3

13. PRETRIAL MOTIONS

General Motions and Content of Motions

     a. Purpose of pretrial motions

     b. Form and style

     c. Jurisdictional  motions

     d. Motions regarding the pleadings

     e. Motions to dispose of case without trial

     f. Motions relating to calendared cases

Trial Documents

          Motion for Judgement on the Pleadings

          Petitioner's Motion for Summary Judgment

          Motion to Consolidate

         Motion for Continuance From Trial Session

         Motion for Leave to File a Response to Objection to Motion for Summary Judgment

PART 4

14. DISCOVERY

Informal Approach - Timeframe

     a. Informal discovery process

     b. Timeframe for discovery

Formal Discovery Procedures

     a. In general

     b. Permissible scope of discovery requests

     c. Formal discovery methods

     d. On-going duty to supplement responses

     e. Protective orders and enforcement of discovery tools

Strategies for the Practitioner to Limit Discovery Responses

     a. Analyze requests carefully and narrowly

     b. Assert privilege

     c. Seek a protective order

Trial Documents

          Sample Branerton Letter

          Respondent's Interrogatories to Petitioners

          Respondent's Request for Production of Documents

          Respondent's Request for Admissions

          Motion for Protective Order

PART 5

15. PRETRIAL NEGOTIATIONS

Dispute Resolutions Options

     a. Referral to appeals

     b. Settlement negotiations with Counsel attorney

     c. Mediation

     d. Arbitration

Stipulation of Facts

     a. Duty to stipulate

     b. Form and filing

Trial Documents

          Stipulation of Settled Issues

          Model Agreement to Mediate

          Joint Motion for Voluntary Binding Arbitration 

          Stipulation of Facts

PART 6

16. TRIAL PREPARATION AND PRESENTATION OF CASE

General Considerations

     a. Burden of Proof

     b. Evidence

     c. Expert witness

     d. Entry of appearance and court etiquette

Preparing for Trial

     a. Pretrial memoranda

     b. Calendar call 

Presenting the Case

     a. Opening statement

     b. Offering stipulation of facts into evidence

      c. Presentation of petitioner's case

      d. Presentation of respondent's case

      e. Closing statement

Trial Documents

         Trial Memorandum for Petitioner

         Respondent's Motion for Extension of Time to File Stipulation and Decision Documents

          Expert Witness Report

          Motion in Limine

          Limited Entry of Appearance

PART 7

17. POST TRIAL MATTERS: BRIEFS, OPINIONS, DECISIONS, AND MOTIONS

Post-Trial Formal Briefs

     a. Timing and order for filing

     b. Form and content

Post-Trial Informal Briefs

     a. Informal briefs generally

Repots, Opinions and Decisions

     a. Introduction

     b. Reports

     c. Opinions

     d. Decisions

     e. Tax Court Rule 155 computation

     f. Date of decision

Post-Trial Motions

     a, Motion for reconsideration of findings or opinion

     b.  Motion to vacate or revise decision 

Trial Documents

         Brief for Petitioner

         Reply Brief for Petitioner

         Decision

         Motion for Reconsideration

PART 8

APPEALS

Decision to Appeal

     b.  The petitioner

     b.  The Government

Perfection of an Appeal

     a. Notice of appeal

     b. Standard of appeal

     c. Venue for appeal

     d. Form of appeal

     e. Bond to stay assessment and collection of tax

     f. Appeal to the U.S. Supreme Court

Finality of Tax Court Decision

     a. Rules of Finality

Trial Documents

          United States Tax Court Forms

          Form 2 - Notice of Appeals to a Court of from a Decision of the United States Tax Court

PART 9

SPECIAL MATTERS

Small Tax Court

     a.  Small tax case procedure

Collection Due Process

     a.  Collection due process

     b. Purpose of I.R.C. section 6320

     c. Appeals consideration

     d. I.R.C. section 6320, notice and opportunity for hearing upon filing of notice of lien/requirements of notice

      e. I.R.C. section 6330, notice and opportunity for hearing before levy

Short Discussion Topics

     Combined Notice

      Notice Rules

     Requirements of notice

     Right to CDP hearing

     Conduct of CDP hearings

     Matters Considered ate CDP hearings

     Liabilities not subject to deficiency procedures

     Judicial Review of CDP hearing

     Jurisdiction

     New issues

     Recent case law

     Statute suspension

     Standard of review by the Court

     Effect of request for judicial review on statute of limitation

     Tax Court rules

     CDP hearing record

Spousal Defenses

     Innocent spouse relief

     Relief easier under I.R.C. section 6015

     I.R.C. section 6015 relief

     Knowledge

      I.R.C. section 6015(c), election of separate liability

      Knowledge of the source of an erroneous item

      Divorced, separated or living apart

      Time deadline

      I.R.C. section 6015(f), equitable liability

      Revenue Procedure 2013-34

     Eligibility to be considered for equitable relief

      Circumstances under which the Service will make streamlined determinations granting equitable relief under I.R.C. sections 66(c) and 6015 (f)

      Limitations

     Refunds

     The Tax Court review in "Stand Alone" petition

     Distinction between should have known and actually knew gives rise to I.R.C. section 6015(c) relief

     Nonelecting spouse entitled to challenge grant of innocent spouse relief to former wife

     Nonelecting ex-spouse may intervene in deficiency case where other spouse is claiming section 6016 relief 

    "Item Giving Rise to Deficiency" in omitted income case disputed