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Publisher: Carolina Academic Press
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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. The Teachers Manual includes not only comprehensive analyses of all problems presented in the coursebook, but also lecture notes on some of the most difficult topics developed by the authors whose combined practice and teaching careers span almost 100 years.
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Chapter 1: STRUCTURE OF TAX ADMINISTRATION
AND SOURCES OF TAX LAW
Chapter 2: REPORTING OBLIGATIONS
Chapter 3: SPOUSAL RELIEF
Chapter 4: EXAMINATION OF RETURNS
Chapter 5: ASSESSMENT PROCEDURES AND
MATTERS RELATING TO THE STATUTES
OF LIMITATIONS ON ASSESSMENT
Chapter 6: EXAMINATION OF PARTNERSHIPS
Chapter 7: TERMINATION AND JEOPARDY
ASSESSMENTS
Chapter 8: TAX COURT LITIGATION OF DEFICIENCY
DETERMINATIONS
Chapter 9: OVERPAYMENTS—CLAIMS FOR
REFUND
Chapter 10: JUDICIAL AND STATUTORY RULES
THAT OVERRIDE THE STATUTES OF
LIMITATION
Chapter 11: PENALTIES
Chapter 12: INTEREST
Chapter 13: COLLECTION OF TAX
Chapter 14: THE SECTION 6672 TRUST FUND
RECOVERY PENALTY
Chapter 15: TRANSFEREE AND FIDUCIARY
LIABILITY