Call-in to our "Conference Room" days, evenings, weekends from the convenience of your Blackberry®, home or office. All conferences convene for approximately 60-to-90 minutes.
Coordinated by Richard Jacobson, PA Certified as Pre-Trial Tax Litigation Support Specialist Assistant Professor of Federal Taxation, Tax Law Institute
James H. Chapman, MPA, IRS Special Enrolled Agent National Tax Practice Institute Graduate Fellow, NAEA Certified as Pre-Trial Tax Litigation Support Specialist Associate Professor of Federal Taxation, Tax Law Institute
Richard C. Cunha, Esq., Admitted to Practice, U.S. Tax Court Assistant Professor of Law, Tax Law Institute
Michael J. Stuart, JD, MPA, Emeritus Professor of Law Director, Tax Law Institute
Beyond the licensing capacity necessary to be admitted to the United States Tax Court bar (Federal bar), the practicing attorney (and USTCP) must demonstrate proficiency in legal reasoning, legal writing (brief and motion preparation) and litigation techniques if he or she does not intend to restrict their practice to small tax cases.
Licensed attorneys may docket cases in any one of three Federal courts and the U.S. Tax Court Practitioner may assist the licensed attorney with appeals of cases from the U.S. Tax Court. Both practitioners will require tax trial advocacy training. For attorneys, who are usually law school graduates, this may seem like a redundant educational exercise. However, the prudent licensed attorney who decides to litigate tax matters in the U.S. Tax Court or U.S. Court of Federal Claims will readily understand and appreciate that the rules of practice and procedure that apply will differ from the Federal Rules of Civil Procedure that apply in U.S. District Court (e.g. United States Tax Court Rules of Practice & Procedure and U.S. Court of Federal Claims Rules of Practice & Procedure).
Our United States Tax Court Small Tax Case & Regular Trial Advocacy Tutorial Program is composed of several live tutorials that allow you to proceed with our help. You may select any four (4) tutorials that reflect your U.S. District Court, U.S. Court of Federal Claims or U.S. Tax Court practice area. This is an ideal program for non-bar lawyers who provide litigation support as well as United States Tax Court Practitioners, Enrolled Agents, and CPAs handling "docketed appeals" before the IRS and licensed U.S. attorneys who wish to concentrate their practice in federal tax litigation but are not strongly grounded in tax-related trial technique and advocacy. Essentially, this program coaches trial advocacy skills sufficient to proceed through litigation of federal tax matters, although negotiated settlements are always encouraged.To follow are our live tutorial offerings:
This is our first- and second-level live tax tutorial that offers comprehensive coverage of the most important tax concepts and principles for a solid grounding in federal taxation. Our treatises and tutorials offer clear and concise explanation of fundamental tax concepts in the framework of today's tax practice. Covering both planning and compliance, the tutorials strike an effective balance between AICPA model curriculum and the favored approaches of the Clerk of the U.S. Tax Court. This tutorial is an opportunity for the licensed attorney to delve into the complex and absorbing study of federal taxation, covering a broad range of subjects beginning with basic concepts and individual taxation. Once the fundamentals are covered, tax accounting and the taxation of partnerships and corporations become the focus. The final section of the tutorial presents estate and gift taxation coverage, along with income taxation of trusts and estates. Deferred compensation, education savings, international tax, and state and local taxation are also addressed.
This live tutorial provides all the information tax professionals need when representing a client before the IRS. It addresses the rapidly changing and increasingly complex area of tax procedure. It is the practitioner’s single most important tool to understanding the procedural changes, IRS restructuring, and ongoing revision of the Internal Revenue Manual and is the key to unlocking the Internal Revenue Code’s and Treasury’s intricate sets of procedural requirements. The electronic treatise used in this tutorial includes opinions from the U.S. Supreme Court, the U.S. Tax Court, and the U.S. Court of Federal Claims, and includes more than 500 references to the Internal Revenue Manual, and more than 5,000 case citations, as well as references to thousands of critical Treasury regulations, revenue rulings, revenue procedures, and IRS internal advice.
Litigation of Civil Tax Controversies is designed to navigate the attorney thoroughly through the procedural nuances peculiar to civil tax litigation in U.S. Tax Court, U.S. district court as well as civil tax claims against the government in the U.S. Court of Federal Claims. It is also a very useful program for non-attorney U.S. Tax Court Practitioners who may assist tax attorneys through appeals taken from the U.S. Tax Court.
Federal Tax Collections, Liens, Levies presents accurate, practical information and guidance in handling problems involving federal tax collections. The discussions offer a unique blend of analysis and interpretation to help attorneys and non-attorney USTCP make the right moves and avoid possible oversights when dealing with client challenges in this area. We review documentation, rules, regulations and court decisions, as well as samples of documents that must be filed with the IRS and/or tax Court, district court or court of claims. Some of the vital topics are: tax assessments, payments of interest, statute of limitations, federal tax lien, relief from tax lien, collection of tax, vicarious responsibility for tax liability and reaching transferees, bankruptcy and insolvency, agreements with the IRS, and estates and gifts. Also presented are issues dealing with grounds for challenging an IRS assessment, satisfying or otherwise lifting a lien and priorities of third-party rights versus IRS rights in competition for taxpayer's property.
Tax Fraud and Evasion I: Money Laundering, Asset Forfeiture, Sentencing is designed for attorneys participating in the defense of civil and criminal tax fraud cases and the CPAs or non-certified public accountants advising them or clients on potential fraud situations. The tutorial discloses the factors the government will consider; the procedures and policies the government adopts to investigate and prosecute; and most importantly, when the IRS will absolutely impose a civil fraud penalty. Specifically, it addresses what IRS special agents will do, what investigative techniques IRS Criminal Investigation uses, whether there are court decisions having facts similar to your client's fraud case, how the IRS investigates using the Federal Grand Jury, what procedures and law defense counsel needs to know and employ in a Grand Jury matter, what the basic defense strategies and techniques are to consider during an IRS criminal investigation, how you should try your client's fraud case in the court, and how the civil fraud penalty is applied in situations involving individuals, partnerships, corporations, and other entities.
Tax Fraud and Evasion II: Offenses, Defenses, Trials, Civil Penalties discusses sentencing under the Sentencing Guidelines for tax, money laundering, currency and related offenses, civil and criminal forfeiture initiated by the IRS, as well as when "willful blindness" will subject a client to criminal charges, civil penalties, or forfeiture. Also discussed: 1) What is the scope of a corporation's right under the Fourth Amendment? 2) When can an individual invoke the Fifth Amendment privilege? The emphasis is upon constitutional questions that often arise in such cases. The partial emphasis of the tutorial is to provide the attorney or United States Tax Court Practitioner with an understanding of the U.S. Constitution, as a "living" document, and its use as an instrument for defense, interpretation, and analysis during the adjudication of certain tax-related offenses
Contact us at 1.888.334.3959
Our United States Tax Court Small Tax Case & Regular Trial Advocacy Tutorial Program is composed of several live tutorials that allow you to proceed with our help. You may select any four (4) tutorials that reflect your U.S. District Court, U.S. Court of Federal Claims or U.S. Tax Court practice area. This is an ideal program for non-bar lawyers who provide litigation support as well as United States Tax Court Practitioners, Enrolled Agents, and CPAs handling "docketed appeals" before the IRS and licensed U.S. attorneys who wish to concentrate their practice in federal tax litigation but are not strongly grounded in tax-related trial technique and advocacy. Essentially, this program coaches trial advocacy skills sufficient to proceed through litigation of federal tax matters, although negotiated settlements are always encouraged.To follow are our live tutorial offerings:
Write 
