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 rulings—retroactive revocation; administrative settlements, closing agreements and compromises; civil penalties; tax return preparer penalties; civil litigation—injunctions, 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 investigations—administrative 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)


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