Course Descriptions

Summer 2014 LLM in Taxation Class Descriptions

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Federal Tax Clinic (Richard Carpenter)
LWVL555

1-4 credit(s), H/P/L/F Graded
Requirement: Skills
Concentration(s): LLM in Taxation (LLMT)
Prerequisite(s): Tax I

This is a hands-on clinical course for students who wish to develop tax controversy skills. Students working under the supervision of the Tax Clinic supervising attorney will represent low income taxpayers in resolving their tax disputes with the IRS. Students will learn client interviewing skills, how to interact with IRS personnel, and how to effectively resolve a client’s federal tax dispute. Students must also be available to participate in Tax Clinic Outreach presentations at various community locations and times. The clinic is graded on a 4-tier Pass-Fail basis. Prerequisite: Tax I.

Law of Tax Appraisals (Hon. David Laro)
LWTE572

3 credit(s), Standard Letter Graded
Concentration(s): LLM in Taxation (LLMT)

Students will learn about the dynamic and developing tax law as it pertains to the statutes, regulations, and cases relating to qualified appraisers, qualified appraisals, the strict versus substantial compliance doctrines, and the reasonable cause exception. Students will gain the knowledge and skills necessary to effectively evaluate appraisers and appraisals taxpayers and their counsel regularly utilize to support tax benefits in circumstances ranging from estates to business transactions. Currently pending in the U.S. Tax Court are approximately 200 cases involving alleged non-compliance with qualified appraiser/appraisal tax regulations. The government estimates that there are billions involved in lost revenue due to taxpayer non-compliance. Finally students will learn the IRS penalties imposed on taxpayers, their attorneys, and appraisers for non-compliance. Students are expected to write short memoranda and make a power point presentation in lieu of a final examination.

State Income Tax Clinic I & II (Craig Shaltes)
LWVL560

1-2 credit(s), H/P/L/F Graded
Requirement: Skills
Concentration(s): LLM in Taxation (LLMT)

This Tax Appeals Assistance Program is a joint effort between USD Legal Clinics and the California State Board of Equalization. Under the supervision of an attorney from the California Taxpayers’ Rights Advocate Office, students will assist taxpayers with their state tax appeals. Students receive legal practice skills training, including interviewing clients, identifying evidence, drafting appeals briefs, and representing clients in negotiations with the State Board and at hearing. The clinic is graded on a 4-tier Pass-Fail basis. No prerequisites.

State Sales & Use Tax Clinic I & II (Michael J. Larkin)
LWVL562

1-2 credit(s), H/P/L/F Graded
Requirement: Skills
Concentration(s): LLM in Taxation (LLMT)

This State Sales & Use Tax Clinic is a joint effort between USD Legal Clinics and the California State Board of Equalization. Under the supervision of an attorney from the California Taxpayers' Rights Advocate Office, students will assist taxpayers at the Petitions stage of proceedings instituted against them by the Franchise Tax Board. Students receive legal practice skills training, including gathering evidence, preparing legal briefs, participating in negotiation proceedings and oral argument at an administrative hearing. The clinic is graded on a 4-tier Pass-Fail basis. No prerequisites.

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