Tax Procedure and Professional Responsibility in Tax Practice

Survey of Internal Revenue Service procedural issues encountered in tax cases, including administrative rulings, closing and compromise agreements, deficiency assessments, injunctions, waivers, refund claims, statutes of limitations, mitigation, interest, and penalties. Also Treasury Department Circular 230, which governs the ethics and disciplinary rules of CPA's in practice before the IRS, and tax research. The course requires a substantial research paper dealing with an important tax issue.