Curriculum Guide · Courses

Professors Todd Ellinwood, Caryn Finley, and Larry Wszalek

LL.M Course 2033 (cross-listed) | 2 credit hours

This course offers first-hand insight into how federal criminal tax cases are investigated and prosecuted. Taught by federal prosecutors from the Department of Justice Tax Division, topics include a survey of frequently charged Title 26 and Title 18 crimes such as tax evasion, filing false returns, and conspiracy. The course chronicles the life of a tax fraud prosecution from its inception at the investigative stage (administrative and/or grand jury) to indictment, pretrial, trial, and sentencing. At each stage, students are presented with challenging issues about sufficiency of the proof, methods of proof, taxpayer defenses, and other ethical issues that impact the theory of prosecution. Student will learn how to examine the strength of evidence of a case, the equities for-and-against prosecution, and trial strategy. Animating these discussions are examples of recent tax prosecutions in federal district court that have either resulted in criminal conviction or acquittal of the taxpayer -- all presented through the eyes of attorneys who have prosecuted criminal tax cases.

Recommended: Taxation I

JD students who have not taken Taxation I and Taxation II should consult Ellis Duncan (ged5@law.georgetown.edu) before enrolling in this course.