Tax Litigation Strategies


Dedicated to Teaching & Learning

One-Day of Simulated Strategic Practice in an Acting United States Tax Court Remote Forum

Hours TBA

Certificate Program


Comprehensive trial practice and litigation guidance on how to deal with tax litigation situations; negotiating with the increasingly aggressive IRS; transfer pricing and other key issues in tax litigation cases; and recent U.S. Tax Court changes in accordance with remote practice during the current pandemic.  


Former Special Trial Judge
United States Tax Court

Professor of Law | Distinguished Judicial Speaker Tax Law Institute | Admitted to Practice Supreme Court of the United States


Former Judicial Law Clerk
United States Tax Court

Professor of Law | Distinguished Author Tax Law Institute | Fmr. IRS Litigator Office of Chief Counsel | Admitted to Practice United States Tax Court | Admitted to Practice State of Indiana


Louis "L.B." Carpenter
Certified Public Accountant
United States Tax Court Practitioner

Lecturer Tax Law Institute | Chief Tax Litigation Counsel U.S. Tax Court | Admitted to Practice United States Tax Court

  • This course provides a judge's and litigator's perspective on best practices for prosecuting the IRS and defending clients in civil tax cases. Featuring the experiences of a former special trial judge of the U.S. Tax Court, a tax litigator, formerly in the IRS Office of Chief Counsel, and a nonattorney CPA-United States Tax Court Practitioner who currently serves as Chief Tax Litigation Counsel for U.S. Tax Court, these experts guide the participants through the preparation and process involved in handling tax disputes in U.S. Tax Court.

  • From understanding the role of the IRS to being aware of new regulations and procedures, these litigation specialists reveal strategies for keeping up with a rapidly evolving tax law environment. Additionally, these top legal strategists offer advice on constructing a successful prosecutorial or defense strategy (in cases where the IRS alleges fraud or some other allegation), managing client expectations, collecting and preparing evidence, and keeping up with strict deadlines in the Tax Code (IRC).

  • Finally, these experts discuss the importance of avoiding common mistakes, conducting through internal investigations, and learning from previous high-profile cases. The different niches represented and the breadth of perspectives presented enable the participants to get inside the minds of these top tax litigation professionals as this experienced judge and two tax litigators of the U.S. Tax Court offer up their thoughts around the keys to navigating a widely-relevant area of litigation. This course will include a review of relevant U.S. Tax Court case law and division opinions.

Courtesy of Apatore Publications


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