Federal Tax Practice and Procedure

Written by a team of practitioners and law professors, Federal Tax Practice and Procedure is the ideal guidebook for understanding how disputes with the IRS arise and are resolved.

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ISBN: 9780820553443
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Written by a team of eight tax practitioners and law professors, Federal Tax Practice and Procedure is the ideal guidebook for understanding how disputes with the IRS arise and are resolved.

Its 18 chapters are divided into four parts:
(1) The Basics: Chapters examine the reform of the IRS during the 1990's and its current structure and organization. Also covered: income tax withholding, calculating estimated taxes, making tax payments, preparing returns and making elections.
(2) Examination of the Tax Return and Assessment of a Deficiency: Chapters explore IRS examination of tax returns and the assessment of tax deficiencies, reaching settlements with the IRS, statutes of limitation on assessment, practicing before the IRS, and obtaining IRS guidance.
(3) Remedies Available to the Taxpayer: Chapters on Tax Court litigation, refunds and appeals.
(4) IRS Tools for Obtaining Unpaid Taxes and Penalizing Taxpayers: Chapters cover collection of taxes, liens and levies, interest, the fraud penalty, civil penalties other than fraud, and criminal penalties and procedure.

The treatise is filled with hypothetical examples where our authors show you how to perform difficult tax calculations and how to apply tax rules and principles in everyday practice. The authors have also included scores of tax planning tips, commentaries and observations on the law, and caveats for the cautious practitioner.

Federal Tax Practice and Procedure is the perfect companion to Matthew Bender’s two-volume treatise, Tax Controversies -- Audits, Investigations and Trials, which provides in-depth coverage of tax fraud, both civil and criminal.

Also includes subject matter index, and tables of Internal Revenue Code sections, Treasury Regulations and IRS rulings and pronouncements.

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Table of contents

Chapter 1 Reform of the Internal Revenue Service

Chapter 2 The Reorganized Service

Chapter 3 Income Tax Withholding and Estimated Taxes

Chapter 4 Tax Payments

Chapter 5 Tax Returns and Elections

Chapter 6 Examinations

Chapter 7 Practice Before the IRS, Guidance and Settlements

Chapter 8 Limitations Periods Applicable to Government Action

Chapter 9 Deficiencies and Tax Court Litigation

Chapter 10 Taxpayer Refunds

Chapter 11 Appeals

Chapter 12 Judicial and Statutory Doctrines that Avoid Limitations Periods

Chapter 13 Liens

Chapter 14 Collection of Taxes

Chapter 15 Interest

Chapter 16 Civil Penalties Other Than Fraud

Chapter 17 The Civil Fraud Penalty

Chapter 18 Criminal Penalties and Procedures