Civil Tax Procedure

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LexisNexis, Dec 1, 2007 - Law - 508 pages
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This new title is one of four releases from the LexisNexis Graduate Tax Series. Civil Tax Procedure embodies the dual goals established for the LexisNexis Graduate Tax Series: to provide graduate tax students with a solid foundation in the applicable rules and to enhance their skills in reading and applying complex statutes and regulations. To this end, the text relies very little on the often-times laborious analysis of cases and other sources that are secondary to the Code and the regulations. Instead, each chapter provides an overview of the substantive content, with emphasis on important issues that are not apparent from the language of the Code and regulations. The problems are designed to require the students to study the assigned sections of the Code and regulations and, for the most part, do not lend themselves to resolution by simply reading the book. Areas that are often difficult for students (and practitioners alike), such as the partnership audit provisions, the innocent spouse rules, judicial and statutory mitigation of the statute of limitations, and transferee and fiduciary liability are addressed in the text and through "real world" problems.
 

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Contents

STRUCTURE OF TAX ADMINISTRATION
Problem
REPORTING OBLIGATIONS
SIGNING AND VERIFYING RETURNS
TIME AND PLACE FOR PAYING
Problem
SPOUSAL RELIEF
ADDITIONAL REQUIREMENTS IMPOSED TO OBTAIN
PRACTICAL DIFFICULTY
TAX COURT LITIGATION OF DEFICIENCY
Problem
JUDICIAL DOCTRINES
Problem 1
Problem 9
HOW AND WHEN TO DISPUTE LATE PENALTIES
CALCULATING THE PENALTY

ADDITIONAL REQUIREMENTS IMPOSED TO OBTAIN
Problem 2
THE FRAUD PENALTY
EXAMINATION OF RETURNS
AUDIT STRATEGIES AND CHOICES
IRS INFORMATION GATHERING
INFORMATION GATHERING BY THE TAXPAYER
CONCLUSION OF EXAMINATION OR ADMINISTRATIVE
Problem
ASSESSMENT PROCEDURES AND MATTERS
STATUTE OF LIMITATIONS ON ASSESSMENT GENERAL
Problems
EXAMINATION OF PARTNERSHIPS
ADMINISTRATIVE PROCEEDINGS
STATUTE OF LIMITATIONS ON MAKING ASSESSMENTS
TERMINATION AND JEOPARDY ASSESSMENTS
OTHER TAXPAYER PROTECTIONS AND OPTIONS
THE SUBSTANTIAL UNDERSTATEMENT PENALTY
THE REASONABLE CAUSE EXCEPTION
INTEREST
COLLECTION OF
ENFORCED COLLECTION
ADMINISTRATIVE AND HYBRID PROTECTIONS
JUDICIAL PROTECTIONS FOR TAXPAYERS AND THIRD
PROCEDURES FOR DETERMINING LIABILITY FOR
PROCEDURES FOR COLLECTING THE PENALTY
TRANSFEREE AND FIDUCIARY LIABILITY
EXTENT OF LIABILITY
Table of Cases
Table of Statutes
Table of Secondary Authorities
Index
PROCEDURAL ASPECTS
Copyright

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