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To access the 2015-16 Supplement to this text, click here. To access the 2016 Letter Update to the Supplement, click here. This casebook teaches the mechanics of tax procedure, while stimulating students to think about the broader issues that underlie its structural framework. This edition of Tax Controversies: Practice and Procedure begins with an overview of civil tax procedure and an in-depth discussion of the federal tax gap and the many approaches to closing it. Several of the next chapters focus on stages in the chronology of a typical tax controversy, from examination through eventual litigation. In addition, two chapters focus on tax research and representing tax clients and a new chapter addresses ethics issues in tax cases. An underlying theme - the extent to which the current procedural rules encourage or discourage voluntary compliance with the federal tax system--runs throughout the book. Suitable for J.D. or LL.M. students, or for use in a tax clinic. This edition contains new chapters on summons enforcement, the U.S. Tax Court, the collection due process procedures, "innocent spouse" relief, and ethics issues. Each casebook chapter includes theory questions and a set of fact-based problems to encourage strategic thinking. Several chapters include optional drafting problems. Teacher's Manual provides detailed answers to the problem sets, suggests approaches to the material, and highlights topics more suitable for an advanced course. Separate Documents Volume, Tax Controversies: Statutes, Regulations, and Other Materials, is also available.
Designed to cover every aspect of a United States Tax Court case from start to finish, Litigating a Case in Tax Court provides detailed guidance and tips on the Tax Court process in an easy-to-read and easy-to-use paper format with an online portal for accessing many sample documents that practitioners can use.
The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
This book covering 30 countries around the globe provides a starting point of practical reference with ready access to the fundamentals of tax litigation in a multi-jurisdictional comparative format. Each chapter covers the following subjects within a specific nation: significant subjects of tax litigation, the legislative framework for both civil tax litigation and criminal tax litigation, tax evasion and other criminal tax offences, pre-court processes, resolving disputes before commencing court proceedings, the elements of the offence in criminal law, early resolution, the trial process, the role of the judge/arbitrator/tribunal members, the commencement of proceedings for both civil law and criminal law, the government response, the burden of proof, documentary evidence, special rules/considerations, disclosure in criminal proceedings, witness evidence, witness preparation, expert evidence, closing the case in civil and criminal trials, the decision in civil and criminal cases, costs, appeals, recent civil law developments and proposals for reform and recent criminal law developments and proposals for reform.
Vol. 3 also issed as rev. 3rd ed. ; rev. 3rd edition of other vols. not planned.