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Federal Tax Litigation

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ALM Product :BOOK
ISBN: 9781588521019
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Tax lawyers across the country have at least one thing in common — the feeling of frustration when trying to figure out the hows and whys of IRS action or inaction. Federal Tax Litigation helps to lift the veil of mystery. Written by a former litigator for the Tax Division of the Justice Department, this book offers an insider's perspective on both the legal issues and practical considerations involved in handling a federal tax controversy. It presents a comprehensive approach to tax litigation, covering audit, appeal, problems resolution office, collection and subsequent judicial proceedings involving the Justice Department.

You'll find coverage of every aspect of federal tax disputes, including: handling tax controversies at all levels of the IRS; alternative dispute resolution procedures; asserting the "innocent spouse defense"; representing a client who is the target of the Criminal Investigation Division; refuting jeopardy assessments; suits against the federal government for overpayments; establishing "reasonable cause" for failure to pay; fighting government suits for recovery of erroneous refunds; recovery of damages for improper government disclosures of tax return information; taxpayer recovery of attorney's fees; tax debts that may be discharged in bankruptcy; grand jury matters; and more. Whether you are experienced or new to the field, Federal Tax Litigation will show you what to expect and help you advise clients in difficult situations. Don't miss this essential guide used in government, private practice and law schools across the country!

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Table of Contents


CHAPTER 1

Assessment, Collection, Settlement and Litigation: An Overview of the Players and the Process



CHAPTER 1A

Litigation



CHAPTER 2

The Trust Fund Recovery Penalty



CHAPTER 3

Independent Contractor Versus Employee



CHAPTER 4

Jeopardy and Termination Assessments



CHAPTER 5

Refunds, Credits, and Abatements



CHAPTER 6

Wrongful Levy



CHAPTER 7

The Reasonable Cause Defense



CHAPTER 8

The Innocent Spouse Defense



CHAPTER 9

Collection Activities Via the Tools of Liens and Levies



CHAPTER 10

Tax Return Preparers and Tax Shelter Promoters



CHAPTER 11

Recovering Monetary Damages from the Federal Government



CHAPTER 12

Recovering Administrative and Litigation Expenses from the Government



CHAPTER 13

Criminal Tax Investigations



CHAPTER 14

Bankruptcy and the IRS



CHAPTER 15

Access to Information from the Federal Government



Index