Tax Litigation


Dedicated to Teaching & Learning

Remote Apprenticeship with Actual Cases Offered concurrently with "Tax Litigation"

​​​​​​​In Association with the Student Trial Practice Program at Hawaii LITC

​​​​​​​Hours TBA

Certificate Program

to qualify to serve as




*EA|USTCPs and CPA|USTCPs are encouraged to train someone in their office as a paralegal aka "Pre-Trial Tax Litigation Support Specialist"
 Acting presiding judge

The Honorable Judge John F. Dean
Guest Judicial Speaker

Fmr. Special Trial Judge on the U.S. Tax Court | Distinguished Judicial Speaker Emeritus at the Tax Law Institute


Acting IRS counsel

Fmr. Judicial Law Clerk of the U.S. Tax Court | Fmr. IRS Litigator in the Office of Chief Counsel | Professor of Law and Distinguished Author at the Tax Law Institute

United States Tax Court Calendar Call with Chief Special Trial Judge Lewis Carluzzo presiding...
Simiulated Calendar Call
United States Tax Court

YouTube Video Courtesy of U.S. Tax Court

Treatise Required

Session 1

Saturday | May 7 | 2022
  • 1. Selection of Tax Litigation Forum
  • 2. US Tax Court Jurisdiction and Structure
  • 3. Statutory Notice of Deficiency
  • 4. Petition for Redetermination
    • Jurisdictional and Procedural Filing Requirements
    • Petitioners
  •  5. Pleadings and Motions
    • Basic Rules
    • Types and Content of Specific Pleadings
    • Amended and Supplemental Pleadings
    • Motions

Session 2

Saturday | May 14 | 2022
  •   6. Stipulations for Trial and Discovery Procedures
    • Stipulations for Trial
    • Discovery Procedures
  •   7. Pretrial Procedures
    • General Pretrial Practice
    • Pretrial Procedural and Evidentiary Motions
    • Settlement Procedures
    • Setting the Case for Trial
  •    8. Trial Proceedings
  •    9. Litigation of Partnership Items
Session 3

Saturday | May21 | 2022
  • 10. Special Proceedings
    • Small Tax Cases
    • Disclosures Actions
    • Collateral and Supplemental Proceedings
    • Other Proceedings
  • 11. Post-Trial Proceedings
    • Opinions, Reports, and Decisions
    • Post-Trial Motions
    • Appellate Review in Court of Appeals
    • Review by Supreme Court
    • Rules of Finality
  •  12. Refund Claims
    • Proper Party to File a Claim for Refund
    • Administrative Requirement as to Claim for Refund
  •  13. Periods of Limitations for Filing Claims for Refund
  •  14. Administrative Procedures on Filing Refund Claim
  •  15. Jurisdictional Prerequisites and Pretrial Considerations
    • Jurisdictional Requirements
    • Pretrial Considerations
  •  16. Special Refund Litigation Considerations
Offered before "Trial Documents" & "Legal Writing for USTCPs"
Awards 9 CPE/CE Credits

26 U.S. Code Title 26 Internal Revenue Code Courtesy of Cornell Law School Legal Information Institute

Please take note...

This course is for newly-admitted nonattorney USTCPs and bar applicants to the United States Tax Court, FATPs preparing to assist in pre-trial tax litigation, and previously-admitted United States Tax Court Practitioners who have limited or no trial practice experience in U.S. Tax Court. Attorneys interested in continuing legal education should visit

Fee $4995

Register +1.202.800.9230

Find out more visit our new website:

Extended Office Hours
Mon - Sat: 09:00 AM - 07:00 PM

Please contact us to determine your qualifications to sit for this course.