Professional Program for Tax Accountants

Dedicated to Teaching & Learning

 Transitioning from IRS Enrolled Agent or CPA to USTCP

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Practice before the Internal Revenue Service as an IRS Enrolled Agent or CPA engaged in Federal Tax Practice and practice in the United States Tax Court as a United States Tax Court Practitioner recognized by the Court as "Tax Litigation Counsel"

Coordinated by James H. Chapman E.A. M.P.A. M.A. Lecturer Emeritus | Federal Tax Research | Tax Law Institute


The Tax Law Institute's combined IRS tax practice and U.S. Tax Court exam prep, trial practice and litigation training program is for both newly- approved and seasoned IRS enrolled agents and CPAs who have an interest in furthering their education in tax accounting and tax law; and who have an aptitude for courtroom advocacy and legal research. Accordingly, it is a Professional Program for Accountants in Federal Tax Practice that leads to approvals to practice before both the IRS and the U.S. Tax Court. It is an excellent career boost for the EA and CPA who have been previously engaged in years of solo-practice. The entire course of study may be completed in 12 months and cost about $33,550-$37, 0000, as of March 2021. It is an entirely remote program, with one requirement to participate in live review (and mock testing) at Georgetown University in Washington DC in November 2021. 

Program Goals

The initial goal is to expose persons to the rewarding career opportunities that can be had as a federally-authorized (Department of Treasury Internal Revenue Service) "IRS Enrolled Agent" and the benefits of advancing from enrolled agent to the professional designation, "United States Tax Court Practitioner" - a non-lawyer who is recognized by the Court as "Tax Litigation Counsel" and "Admitted to Practice, U.S. Tax Court". The second goal of the program is to prepare exceptional individuals with years of tax practice experience as support staff for our free tax clinic in Hawaii and, eventually, for a teaching position at the Tax Law Institute and/or with U.S. Tax Court Litigators. Qualifications sought are determined by our current and future staffing needs. Applicants are required to make known their interest in the program via telephone or email to our Program Director. 

Transitioning from IRS Special Enrolled Agent or CPA to Advocate and Tax Litigator

Success in all three parts of the SEE (or in the CPA examination) qualifies the applicant to begin the extended non-attorney bar review followed by the pre-exam review that prepares the EA/CPA to sit for the U.S. Tax Court Non-attorney Examination. During this time, the Applicant/EA/CPA would continue to engage in solo-tax practice/return preparation and/or audit representation but s/he would do so in consultation with a TLI-authorized FATP, until such time when the Applicant/EA/CPA sits for the non-attorney exam. This consultative experience will payoff when the applicant passes the bar exam. The Tax Court non-attorney bar exam is administered once, every other year in Washington DC. If the EA/CPA receives a "pass letter" from the Tax Court then he/she will be subjected to a background check by the FBI. If an applicant is deemed "to be of good character" by the FBI, then the Tax Law Institute will "sponsor" (recommend) the successful bar applicant to the U.S. Tax Court Office of Admissions. The Tax Law Institute provides to each successful test applicant the two required letters of recommendation. The successful applicant is then sworn-in as a "Member of the Bar United States Tax Court" and issued a bar registration number. The bar registration number allows the newly-admitted USTCP to setup his/her practice as tax litigation counsel to prospective petitioner-taxpayers, who often require their services. 

EA/CPA-USTCP Career Development

Stage 1

The newly-admitted EA/CPA-USTCPs then enter the "Apprenticeship Program" managed by the Tax Law Institute and affiliate, U.S. Tax Court Litigators.  The program includes courses in tax litigation, trial documents preparation, and legal writing for nonlawyers. The apprenticeship also includes remote, pro bono student trial practice at our low income tax clinic in Hawaii. Afterwards, the apprentice is ready for courtroom practice as a United States Tax Court Practitioner (aka Tax Litigation Counsel). The newly-admitted EA/CPA-USTCP then joins the 2022 Winter Session of the Tax Court. 

Stage 2

The newly admitted EA/CPA-USTCP will enjoy practice privileges that extend throughout the national jurisdiction, including U.S. territories or anyplace the U.S. Tax Court holds session. Whereas, a state-licensed attorney is restricted from practice across state lines under rules of reciprocity - restrictions imposed by state bar authorities. In contrast, no USTCP can be prevented from accepting a case in Oregon or another case in Florida on the grounds that he or she is not approved to practice there. Just so long as a Federal courthouse exist, and the U.S. Tax Court can hold session, the USTCP can appear for trial anywhere nationwide. See "USTCP Defined"


Most newly-approved EA/CPA-USTCPs will be encouraged by us to enter solo-practice - usually the most lucrative option. (As mentioned earlier, a select few will be offered program/case management/teaching positions with TLI or USTCL.)  As a point of information, average industry-standard for annual incomes, in 2019-20, for an IRS Enrolled Agent engaged in tax return preparation and audit representation was $50,000-$120,000, or more. Annual legal fees collected by an EA who is also a United States Tax Court Practitioner and engaged in small ("s") case practice (administrative resolutions) and/or regular case practice (pays more), averaged $75,000-$150,000, or more. All figures are affected by locality, full- or part-time service, and practice concentrations and specializations. On the other hand, CPAs engaged in Federal Tax Practice and working similar types of cases will fall into an entirely different income bracket, usually slightly higher than their EA counterparts. Regardless, according to recent program graduates, successful applicants will make 3-5 times what they spend for this program during their first year of practice after securing the bar registration number and completing the Professional Program apprenticeship component.

Price: $33,550-$37,000 + Nominal Fees  (as of April 2021)

  • Professional Program for Accountants in Federal Tax Practice - (EA and CPA) (Books Included + Private Tutorials) 
    • SEE Preparation - $4995 or Virtual Pre-exam Tax Bar Review - $4995 (Select either)
    • Extended Tax Court Bar Review (Non-attorney Bar Exam Prep) Program - $11,980
    • Digital Study Platform - $1695
    • Apprenticeship - 
      • Tax Litigation for USTCP - $4995
      • Mock Branerton Conference for USTCP - $1595
      • Trial Documents for USTCP - $2995
      • Legal Writing for USTCP - $2995
    • Practice Area Specialization Course(s) - $3995 (Select from among several choices)


Please click the following link to visit Fees/Policy - Tax Law Institute

Please watch the following video to hear about the SEE if you are interested in becoming an IRS Enrolled Agent

For more information +1.202.800.9230