Tax Controversies: Audits, Investigations, Trials

Author: Robert S. Fink (Author)
Guide to all stages of a tax examination, investigation, litigation and prosecution -- civil or criminal.
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Print Book: 2 Volumes; Looseleaf; updated annually.
$ 4,204.00
In Stock ISBN: 9780820554631
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Guide to all stages of a tax examination, investigation, litigation and prosecution -- civil or criminal -- including the following:

  • A discussion of the final regulations regarding the tax controversies that can be brought before the Independent Office of Appeals.
  • A new chapter on Tax Litigation that covers refunds versus protests, benefits and burdens of Tax Court versus Federal District Court, choosing between a Federal District Court and Claims Court, involvement of the U.S. Department of Justice, pretrial procedures, and much more.
  • Notice of Third-Party Summons and Taxpayer’s Right of Intervention, including discussion of Proposed Treasury Regulations Section 301.7602-2(d)(5), which provides exceptions to the 45-day advance notice requirement.
  • Use of the Freedom of Information Act in Tax Litigation that discusses the updated procedures for submitting a Freedom of Information Act request.
  • A new chapter on Bankruptcy and the IRS that covers the Bankruptcy process, Bankruptcy Court determinations of income tax, inter-agency jurisdiction and settlement authority between the IRS and the Department of Justice, determining tax lien priorities, attorney’s fees recovery, debt forgiveness, and includes Practice Tips, and much more.
  • The various methods of proof, including the direct and indirect method and information from the recently updated IRM 9.5.9 Methods of Proof.

Volume 2 augments these discussions by providing a useful collection of valuable source material, including:

  •  Sample jury charges;
  •  Important IRS forms;
  •  A wide selection of Civil and Criminal litigation forms.

Tables of Cases and Statutes and an Index are also provided.

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