Curriculum Guide · Courses

Professors Peter Panuthos and Robert Pomerance

LL.M Seminar 2012 (cross-listed) | 2 credit hours

This workshop offers a guide to the effective representation of individual taxpayers, particularly those with low income, throughout the cycle of a tax dispute with the IRS, beginning at the administrative level and culminating in litigation in the U.S. Tax Court. We start with an overview of income tax issues that commonly affect these taxpayers and give rise to frequent litigation, including collection due process, innocent spouse relief and dependency exemptions. Acting as lawyers for the parties in two hypothetical cases presenting issues of that kind, students will conduct client interviews and appeals office hearings, draw up Tax Court petitions and briefs, and engage in other exercises designed to impart the skills of effective advocacy and to convey a practical understanding of the tax controversy process. An introductory course in taxation is a prerequisite. A course in tax practice and procedure is recommended but not required. Students will be graded on written assignments and on class performance during the semester.

Prerequisite: Taxation I