FEDERAL CIVIL TAX LITIGATION PRACTICUM: INITIAL PLEADINGS
(LAWW-4051) - 2 UNITS
This mixed lecture and practicum course will introduce students to the beginning stages of Federal civil tax litigation in District Court. We will begin by discussing the necessary considerations when filing a tax controversy, including choice of venue as well as timing and the statute of limitations. We will then use a core model case to examine litigation strategies and to draft a responsive and dispositive pleading. This aspect of the course will include a discussion of the relevant Federal Rules of Civil Procedure. Students will spend the final day arguing their dispositive motion at a mock hearing. While the course will be centered around tax litigation and the core model case will include a substantive tax topic, the course is designed to provide a general introduction to the beginning stages of Federal civil litigation. Therefore, no background in tax is necessary.