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This casebook teaches the mechanics of tax procedure, while stimulating students to think about the broader issues that underlie its structural framework. This edition of Tax Controversies: Practice and Procedure begins with an overview of civil tax procedure and an in-depth discussion of the federal tax gap and the many approaches to closing it. Several of the next chapters focus on stages in the chronology of a typical tax controversy, from examination through eventual litigation. In addition, two chapters focus on tax research and representing tax clients and a new chapter addresses ethics issues in tax cases. An underlying theme - the extent to which the current procedural rules encourage or discourage voluntary compliance with the federal tax system - runs throughout the book.

•   Suitable for J.D. or LL.M. students, or for use in a tax clinic.
•   This edition contains new chapters on summons enforcement, the U.S. Tax Court, the collection due process procedures, "innocent spouse" relief, and ethics issues.
•   Each casebook chapter includes theory questions and a set of fact-based problems to encourage strategic thinking. Several chapters include optional drafting problems.