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Federal Tax Litigation
Incisive Media, Pages: 950
Tax lawyers across the country have at least one thing in common-the feeling of frustration when trying to figure out the hows and whys of IRS action or inaction. Federal Tax Litigation helps to lift the veil of mystery. Written by a former litigator for the Tax Division of the Justice Department, this book offers an insider's perspective on both the legal issues and practical considerations involved in handling a federal tax controversy. It presents a comprehensive approach to tax controversy—audit, appeal, problems resolution office, collection and subsequent judicial proceedings involving the Justice Department—all in light of the IRS Restructuring and Reform Act of 1998 and the reorganization of the IRS. This publication is updated throughout the year as needed
You'll find coverage of every aspect of federal tax disputes, including: handling tax controversies at the administrative audit and appeals levels of the IRS; alternative dispute resolution procedures; asserting the “innocent spouse defence”; representing a client who is the target of the Criminal Investigation Division; refuting jeopardy assessments; suits against the federal government for overpayments; establishing “reasonable cause” for failure to pay; fighting government suits for recovery of erroneous refunds; recovery of damages for improper government disclosures of tax return information; taxpayer recovery of attorney's fees; tax debts that may be discharged in bankruptcy; grand jury matters; and more. Whether you are experienced or new to the field, Federal Tax Litigation will show you what to expect and help you advise clients in difficult situations. Don't miss this essential guide used by practitioners in government and private practice and by law schools across the country!
Authors Bio:
Susan A. Berson
Susan A. Berson, a former senior trial attorney with the U.S. Department of Justice, Tax Division, is a principal with the Tax Litigation Group LLC, based in Kansas City. Ms. Berson has litigated tax cases before judges and juries in numerous federal district and bankruptcy courts. The recipient of an Outstanding Attorney Award from the Justice Department, and voted Best of the Bar by her peers, she has also written and lectured at seminars about litigating cases against the government
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