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The essential tax controversy reference for litigators.
Litigation of Federal Civil Tax Controversies, Second Edition examines all the crucial elements that must be considered in pretrial, trial, and post-trial. It's designed for use by practitioners at all levels, from novice to expert, and organized to provide fast answers to the hardest questions.
No other reference work can navigate the practitioner so thoroughly through the procedural nuances peculiar to tax litigation at all stages, from selection of forum and pretrial motions through appeals and recovery of judgments.
Includes a complete discussion of:
- Statute of limitations issues
- IRS deficiency procedures
- Challenging the deficiency in U.S. Tax Court
- Tax Court pleading and motion practice
- Conducting a Tax Court trial
- Special Tax Court proceedings, such as small tax cases, motions to restrain assessment or collection, and motions to review jeopardy assessments or levies
- Pursuing refund claims before the IRS and refund actions in the U.S. District Court and Court of Federal Claims