Curriculum Proposal System
Course Details

Prerequisites (list each individually, one course per line, with course number and title)
Current Completion of Master of Tax foundation courses. New Admission to Master of Tax program or special permission. New prerequisites to be checked at time of registration? yes
Corequisites (list each individually, one course per line, with course number and title)
Current New New corequisites to be checked at time of registration? no
Bulletin description
In-depth study of administration and procedures of Internal Revenue Service and responsibilities of tax practitioner.
Web Components
Textbook selection
Saltnuan, Michael I., IRS Practice and Procedure Second Edition (published by Warren, Garham & Lamont) Harold J. Heltzer, Howard M. Weinman, Charles C. Hwang, Robert L. Willmore, Alex E. Sadler, Coping with IRS Audits Treasury Department Circular No. 230
Rationale
The Master of Tax program has changed and coverage in the course has been expanded to accomodate the program change. In addition, the topics covered are quite complex and require more time than was originally allocated necessitating a change in credits. Classes are scheduled in order to expedite the amount of time needed to complete the program. Once a student begins the program there is a specific sequence of courses that will be available for completion eliminating the need for a set of foundation courses that should be completed first.
Syllabus
UNIVERSITY OF AKRON COLLEGE OF BUSINESS ADMINISTRATION MASTER OF TAXATION PROGRAM Tax Practice and Procedure DAVID J. LEWIS, ESQ., CPA Course No. 6200:648 080 Buckingham, Doolittle & Burroughs, LLP SPRING, 2006 P.O. Box 1500, 50 South Main Street Akron, Ohio 44309 Email: dlewis@bdblaw.com Direct Dial: 330-258-6407 Direct Fax: 330-252-5407 Home: 330-650-9681 GENERAL INFORMATION TIME: Mondays, 6:05 p.m. - 7:45 p.m. LOCATION: CBA, Room TEXT: Saltnuan, Michael I., IRS Practice and Procedure Second Edition (published by Warren, Garham & Lamont) Harold J. Heltzer, Howard M. Weinman, Charles C. Hwang, Robert L. Willmore, Alex E. Sadler, Coping with IRS Audits Treasury Department Circular No. 230 Other resource materials that would be beneficial include: DNA Tax Management Portfolios: • Civil Tax Penalties, No. 634 • Federal Tax Collection Procedure, No. 638 • IRS National Office Procedures - Rulings, Closing Agreements, No. 104 • IRS Procedures: Audits and Appeals, No. 465 • Limitations Periods, Interest on tJnderpayments and Overpayments, and Mitigation, No. 627 • Practice Before the IRS and Circular 230, No. 147 • Tax Court Litigation, No. 630 Internal Revenue Code of 1986 IRS Regulations UNIVERSITY OF AKRON COLLEGE OF BUSINESS ADMINISTRATION MASTER OF TAXATION PROGRAM Tax Practice and Procedure DAVID J. LEWIS, ESQ., CPA Course No. 6200:648 080 Buckingham, Doolittle & Burroughs, LLP SPRING, 2006 P.O. Box 1500, 50 South Main Street Akron, Ohio 44309 Email: dlewis@bdblaw.com Direct Dial: 330-258-6407 Direct Fax: 330-252-5407 Home: 330-650-9681 GENERAL INFORMATION TIME: Mondays, 6:05 p.m. - 7:45 p.m. LOCATION: CBA, Room TEXT: Saltzman, Michael I., IRS Practice and Procedure Second Edition (published by Warren, Garham & Lamont) Harold J. Heltzer, Howard M. Weinman, Charles C. Hwang, Robert L. Willmore, Alex E. Sadler, Coping with IRS Audits Treasury Department Circular No. 230 Other resource materials that would be beneficial include: BNA Tax Management Portfolios: • Civil Tax Penalties, No. 634 • Federal Tax Collection Procedure, No. 638 • IRS National Office Procedures - Rulings, Closing Agreements, No. 104 • IRS Procedures: Audits and Appeals, No. 465 • Limitations Periods, Interest on Underpayments and Overpayments, and Mitigation, No. 627 • Practice Before the IRS and Circular 230, No. 147 • Tax Court Litigation, No. 630 Internal Revenue Code of 1986 IRS Regulations REGISTRATION: Students whose names do not appear on the class list will not be permitted to participate (take exams or receive credit) without first showing proof of registration (schedule of classes and statement of account) in accordance with University policy. WITHDRAWAL POLICY: I will follow the established University procedure on course withdrawals. I will permit withdrawal and sign withdrawal slips at any time providing such does not run afoul of University rules or procedures. GRADING: Your course grade will be based on your final exam. I anticipate that the exam will consist of a variety of questions (e.g.: multiple choice, true-false, and possibly short essay). I intend to utilize the plus/minus system of grading. ATTENDANCE: Class attendance is mandatory. OFFICE HOURS: My office hours will be after class. Also, you may make an appointment for other times by making arrangements with me before or after class or by telephone. SUBSTITUTE: In the event I am unable to attend any class, I will attempt to arrange for a substitute. In the event I am unable to attend, a message informing you of class cancellation will be left at the telephone number or e-mail address you designate for such notifications. SPRING SEMESTER, 2006 COURSE NO. 6200:648-080 CLASS NO. SUBJECTS 1. Course Introduction — IRS organization and volunteer tax system 2. Examination Process: revenue agents, information document requests (“IDRs”), summons, documents, special issues, and power of attorney 3. Examination Process continued: client involvement, statute of limitations, refunds, consents to extend statutes of limitations, IRS audit Forms 2848, 870, and 872. IRC §~6501 et seq. 4. Examination Process continued: privileges. IRC §7525. 5. Examination Process continued: 30-day letters, protests 6. Examination Process continued: eggshell audits 7. Appeals: organization and function, case resolution, and sample protests 8. Appeals Process: negotiation 9. Special Issues: practitioners’ responsibilities and return preparation standards 10. Special Issues: Treasury Circular 230, mitigation of statute of limitations-IRC § § 1311-1314, judicial doctrines of estoppel, and offset 11. Tax Litigation: refund litigation, Tax Court, and choice of forum 12. Tax Litigation: analysis of forum selection factors, interest rules and IRC §660 1 et seq. 13. Penalties: IRC §~6662 et seq. 14. Criminal: investigations, grand jury, procedure, and elements of tax crimes 15. Collection: IRC §632 1 et seq., statute of limitations, offers in compromise, installment agreements, and responsible party liability under IRC §6672. At the conclusion of each class, I will advise you of what to expect for the next class. If you are absent, it is your responsibility to learn what will be the next week’s topics.
Bibliography
DNA Tax Management Portfolios: • Civil Tax Penalties, No. 634 • Federal Tax Collection Procedure, No. 638 • IRS National Office Procedures - Rulings, Closing Agreements, No. 104 • IRS Procedures: Audits and Appeals, No. 465 • Limitations Periods, Interest on tJnderpayments and Overpayments, and Mitigation, No. 627 • Practice Before the IRS and Circular 230, No. 147 • Tax Court Litigation, No. 630 Internal Revenue Code of 1986 IRS Regulations Home: 330-650-9681