Curriculum Guide · Courses

Professor Brian Kaufman

LL.M Seminar 771 | 3 credit hours

In this workshop course, students will work through a hypothetical administrative Federal income tax controversy, from pre-audit considerations through the initiation of litigation. Hypothetical fact patterns will be used throughout the semester and students will utilize these fact patterns to research, draft and discuss various administrative assignments based upon issues that arise in a typical Internal Revenue Service administrative audit and appeals process. These assignments will culminate in moot IRS Appeals conferences toward the end of the semester. Activities will involve drafting written responses to Information Document Requests, preparing legal arguments in response to IRS Notices of Proposed Adjustments, drafting Tax Protest letters, arguing issues at mock IRS Appeals conferences, negotiating settlements with the IRS, and drafting a Tax Court petition.

Prerequisite: A basic course in federal income taxation, such as Taxation I.

This course will require weekly written assignments; 2 oral presentations with written submissions; and class participation.