Taking Off the Gloves: What to Expect in U.S. Tax Court (Video) (Course Id 2705)

• Who is this course for?
  This course is designed for CPAs, IRS Enrolled Agents, and other professionals who need Continuing Professional Education (CPE) credits and are interested in understanding U.S. Tax Court procedures.

• What is this course about or what problem does this course solve?
  The course explains procedural and evidentiary rules specific to U.S. Tax Court, helping professionals navigate tax litigation effectively.

• How can the knowledge from this course be used?
  Learners can apply the knowledge to represent or advise clients in Tax Court, understand procedural differences, and prepare for litigation involving IRS disputes.

• Why is this course important to a CPA, Accountant, or IRS Enrolled Agent?
  It provides technical insights into Tax Court processes and litigation strategies that are directly relevant to tax practitioners handling IRS disputes.

• When is this course relevant or timely?
  This course is relevant upon release in 2025, particularly for professionals preparing for or currently involved in tax litigation.

• How is a course like this consumed or used?
  It is delivered as a video-based, self-study course online, requiring completion of review questions and a final exam to earn CPE credits.

This presentation will cover the following. Tax Court is based in Washington, D.C., but its judges travel to hear cases on regular calendars in various cities around the country. **At trial, the TP may be represented by anyone admitted to practice before the Tax Court, which includes non-attorneys who have passed an exam. The IRS is represented in Tax Court by attorneys from the IRS Chief Counsel’s Office. **U.S. Tax Court applies the rules of evidence applicable in trials w/o a jury in the U.S. District Court of the District of Columbia. U.S. Tax Court follows its own procedural rules. In this presentation, we will deliver into these rules.

Video - NASBA QAS - NASBA Registry - IRS Enrolled Agents - 2705

Course Learning Objectives

1. How does the requirement for a taxpayer's last known address impact the validity of a notice of deficiency?
o This question encourages exploration of the legal implications surrounding taxpayer notifications.
2. In what ways can the IRS justify a deficiency that was not specified in the original notice?
o This prompts an analysis of the IRS's authority and the legal processes involved in tax disputes.
3. What are the procedural differences between small tax cases and regular tax cases in the Tax Court?
o This invites a comparison of the two types of cases, highlighting the unique aspects of small tax cases.
4. How does the Golsen rule influence the outcome of tax cases in the Tax Court?
o This question seeks to understand the implications of appellate precedents on Tax Court decisions.
5. What factors should a taxpayer consider when deciding whether to litigate in Tax Court?
o This encourages critical thinking about the strategic decisions involved in tax litigation.
6. How does the burden of proof shift between the IRS and the taxpayer in tax litigation?
o This question allows for discussion on evidentiary requirements and legal strategies in tax cases.
7. What role does the Taxpayer Advocate’s Office play in the context of a notice of deficiency?
o This invites examination of the support systems available to taxpayers facing IRS actions.
8. How do the Tax Court's rules of evidence compare to those in federal district courts?
o This question encourages a detailed comparison of judicial processes in different types of courts.
9. What consequences might arise if a taxpayer fails to appear at a calendar call in Tax Court?
o This prompts an exploration of the potential outcomes and penalties for non-compliance in court.
10. In what circumstances can a taxpayer raise new issues during the litigation process in Tax Court?
o This encourages discussion on the flexibility and limitations of the litigation process.
11. What are the implications of the presumption of correctness in tax court proceedings?
o This question invites analysis of how this legal principle affects the burden of proof in tax cases.
12. How do settlement negotiations typically unfold in the context of Tax Court cases?
o This encourages an understanding of the negotiation process and factors influencing settlements.

Chapter 1 - Taking Off the Gloves: What to Expect in U.S. Tax Court

Chapter 1 Review Questions