This course offers an overview of federal tax practice and focuses not only on compliance issues, but covers controversies both civil and criminal between the Government and the taxpayer. The rights and remedies of the taxpayer, settlement options, negotiations, appeals procedures (both administrative and judicial) are addressed.

More particularly, the course will cover the organization of the IRS, its pronouncements, access to information from the IRS, the ethical responsibility of the attorney, accountant and enrolled agent in the representation of the taxpayer, the tax return, the notice of deficiency, assessments, penalties and interests, refunds, statute of limitations, the collection process, criminal tax investigation and prosecution, and constitutional issues in federal tax practice. The course will be taught using a combination of practical problem solving and lectures.