Taking Off the Gloves: What to Expect in U.S. Tax Court

Receiving a Notice of Deficiency (often called a 90-day letter) from the IRS is a critical turning point for any taxpayer. This course pulls back the curtain on the complex and highly specialized world of the U.S. Tax Court. Designed as a practical roadmap, it guides practitioners through the entire lifecycle of a tax controversy—from the conclusion of an IRS audit to the final entry of a Tax Court decision.

The document summarizes key aspects of procedures and precedents in U.S. Tax Court. It describes the Tax Court's structure and jurisdiction over tax deficiency cases. It explains procedures for docketing cases, discovery, pre-trial memoranda, and precedent from appeals. The document also covers the small tax case procedure and calendar calls. Finally, it discusses the review process for cases decided by special trial judges.

At trial, the TP may be represented by anyone admitted to practice before the Tax Court, which includes non-attorneys who have passed an exam. The IRS is represented in Tax Court by attorneys from the IRS Chief Counsel’s Office.

Attendees will learn how to navigate the court's unique rules of practice, handle aggressive IRS positions, manage the strict petition timelines, and strategically position a case for a favorable settlement or trial.

Your Benefits For Attending:

Explains that U.S. Tax Court is based in Washington D.C. but judges travel to hear cases in cities around the country.
Covers who may represent a taxpayer in Tax Court, including non attorneys who have passed the required exam.
Explains how U.S. Tax Court applies rules of evidence used in trials without a jury.
Worth 8.0 CPE and 8 IRS credits as a self study video course on U.S. Tax Court procedures, requiring a 40 question final exam preceded by 25 review questions (optional) and a 70% passing score.

Topics Covered:

By the end of this course, you will be able to execute the following:

How does the requirement for a taxpayer's last known address impact the validity of a notice of deficiency?
In what ways can the IRS justify a deficiency that was not specified in the original notice?
What are the procedural differences between small tax cases and regular tax cases in the Tax Court?
How does the Golsen rule influence the outcome of tax cases in the Tax Court?
What factors should a taxpayer consider when deciding whether to litigate in Tax Court?
How does the burden of proof shift between the IRS and the taxpayer in tax litigation?
What role does the Taxpayer Advocate’s Office play in the context of a notice of deficiency?
How do the Tax Court's rules of evidence compare to those in federal district courts?
What consequences might arise if a taxpayer fails to appear at a calendar call in Tax Court?
In what circumstances can a taxpayer raise new issues during the litigation process in Tax Court?
What are the implications of the presumption of correctness in tax court proceedings?
How do settlement negotiations typically unfold in the context of Tax Court cases?

Who Should Attend?

This course is highly recommended for:

Tax Attorneys and Litigators looking to expand their federal tax litigation practice or brush up on specialized Tax Court rules.
Certified Public Accountants (CPAs) who represent clients during aggressive IRS audits and need to know when and how to transition a case to legal counsel.
Enrolled Agents (EAs) seeking a deeper understanding of the IRS litigation framework to better advise clients on their controversy options.
Corporate Tax Directors and Financial Advisors who manage high-stakes tax exposure and want to understand the risks and timelines of docketing a case.

Credits and Other information :

IRS CPE Credits: 2.0 TAX

Session Prerequisites and preparation: None

Session learning level: Basic

Location: Virtual/Online

Delivery method: Group Internet Based

IRS Course ID: DFFSC

Attendance Requirement: Yes

Session Duration: 120 Min

Case Studies and Live Q&A session with speaker

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