Federal Tax Litigation
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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
Assessment, Collection, Settlement and Litigation: An Overview of the Players and the Process
The Trust Fund Recovery Penalty
Independent Contractor Versus Employee
Jeopardy and Termination Assessments
Refunds, Credits, and Abatements
The Reasonable Cause Defense
The Innocent Spouse Defense
Collection Activities Via the Tools of Liens and Levies
Tax Return Preparers and Tax Shelter Promoters
Recovering Monetary Damages from the Federal Government
Recovering Administrative and Litigation Expenses from the Government
Criminal Tax Investigations
Bankruptcy and the IRS
Access to Information from the Federal Government