Litigation of Federal Civil Tax Controversies

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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

• Kafka & Cavanagh: Litigation of Federal Civil Tax Controversies
  • Chapter 1: Selection of Tax Litigation Forum
  • Chapter 2: Tax Court Jurisdiction and Structure
  • Chapter 3: Statutory Notice of Deficiency
  • Chapter 4: Petition for Redetermination
    • A. Jurisdictional and Procedural Filing Requirements
    • B. Petitioners
      • Appendix Reference Materials
  • Chapter 5: Pleadings and Motions
    • A. Basic Rules
    • B. Types and Contents of Specific Pleadings
    • C. Amended and Supplemental Pleadings
    • D. Motions
      • Appendix Answer
  • Chapter 6: Stipulations for Trial and Discovery Procedures
    • A. Stipulations for Trial
    • B. Discovery Procedures
    • Appendix Reference Materials
  • Chapter 7: Pretrial Procedures
    • A. General Pretrial Practice
    • B. Pretrial Procedural and Evidentiary Motions
    • C. Settlement Procedures
    • D. Setting the Case for Trial
  • Chapter 8: Trial Proceedings
    • Appendix Reference Materials
  • Chapter 9: Litigation of Partnership Items
  • Chapter 10: Special Proceedings
    • A.. Small Tax Cases
    • B.. Disclosure Actions
    • C.. Collateral and Supplemental Proceedings
    • D.. Other Proceedings
  • Chapter 11: Post-Trial Proceedings
    • A. Opinions, Reports, and Decisions
    • B. Post-Trial Motions
    • C. Appellate Review in Court of Appeals
    • D. Review by Supreme Court
    • E. Rules of Finality
    • Appendix Reference Materials
  • Chapter 12: Refund Claims
    • A. Proper Party to File a Claim for Refund
    • B. Administrative Requirements as to Claim for Refund
  • Chapter 13: Periods of Limitations for Filing Claims for Refund
  • Chapter 14: Administrative Procedures on Filing Refund Claim
  • Chapter 15: Jurisdictional Prerequisites and Pretrial Considerations for Tax Refund Litigation
    • A. Jurisdictional Prerequisites
    • B. Pretrial Considerations
  • Chapter 16: Special Refund Litigation Considerations
  • Chapter 17: Commencement of Tax Refund Suit and Initial Pleadings
    • Appendix Reference Materials
  • Chapter 18: Pretrial Procedure
    • Appendix Reference Materials
  • Chapter 19: Post-Trial Procedures
    • Appendix Reference Materials
  • Chapter 20: Other District Court Civil Tax Litigation
    • A. Suits Commenced by the United States
    • B. Suits Commenced by Taxpayers and Third Parties
      • Appendix Reference Materials
  • Chapter 21: Actions for Declaratory Judgment
  • Chapter 22: Res Judicata and Collateral Estoppel in Civil Tax Litigation
  • Chapter 23: Recovery of Attorney's Fees and Extraordinary Costs in Civil Tax Litigation
    • Appendix Reference Materials
    • Appendix Reference Material
    • Appendix Reference Materials
    • Appendix Reference Material
  • Appendix A. Rules of the United States Court of Federal Claims
  • Appendix B. Rules of Practice and Procedure of the United States Tax Court
  • Appendix C. Notes to Rules of Practice and Procedure of the United States Tax Court