Civil and Criminal Tax Procedure | L4489
Statute of limitations on assessment/collection of deficiencies, definition of deficiency, restrictions on assessment and collection; statute of limitations on overpayments, claims and suits for refund, and limitations for criminal prosecutions; regulations and rulingsretroactive revocation; administrative settlements, closing agreements and compromises; civil penalties; tax return preparer penalties; civil litigationinjunctions, jurisdiction of Tax Court, District Court, and Court of Claims, small claims procedure, authority to increase deficiencies, choice of forum; jeopardy assessments and termination of taxable years; criminal tax investigationsadministrative summons, document production (taxpayer and third party), constitutional protections, common law privileges, strategies; professional responsibilities and ethics for the tax practitioner.
Prerequisites: Cross Listed Tax Course (TAX 4310) -Please see Graduate Tax for prerequisites.
Credit Hours: 2 to 4
ULW: This course does not satisfy the Upper Level Writing requirement (ULW)