Course Descriptions

Summer 2016 LLM in Taxation Class Descriptions

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Federal Tax Clinic I (Richard Carpenter)
LWVL555

1-4 credit(s), H/P/L/F Graded
Requirement(s): 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.

Students must attend a mandatory orientation on Friday, June 10, 2016 at noon in WH 3C.

Federal Tax Clinic II (Richard Carpenter)
LWVL556

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

Clinic II interns refine their skills, working on complex cases and cases already begun as Clinic I interns. Students may mentor first time clinic participants, serve as lead attorney on cases, and have additional opportunities to appear in court or administrative proceedings. Supervising attorneys/adjunct professors provide individualized coaching, based on the Clinic II interns’ needs and interests. Prerequisite: Successful completion of Clinic I in the same clinic. The clinic is graded on a 4-tier Pass-Fail basis.

Law of Tax Appraisals (Hon. David Laro)
LWTE542

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 (Craig Shaltes)
LWVL560

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

This litigation clinic, also known as the "Taxpayer Appeals Assistance Program (TAAP) - Franchise and Income Tax," is a joint effort between the USD Legal Clinics and the California State Board of Equalization (BOE). Under supervision of an attorney from the BOE's Taxpayer Rights Advocate Office, students assist taxpayers with state income tax disputes against the California Franchise Tax Board (FTB). Students receive legal practice skills training, including gathering and identifying evidence, drafting legal briefs, and representing clients/taxpayers in negotiations with the FTB and at oral hearings before the BOE.

Students must attend a mandatory orientation on Friday, June 10, 2016 at noon in WH 3C.

State Income Tax Clinic II (Craig Shaltes)
LWVL561

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

Clinic II interns refine their skills, working on complex cases and cases already begun as Clinic I interns. Students may mentor first time clinic participants, serve as lead attorney on cases, and have additional opportunities to appear in court or administrative proceedings. Supervising attorneys/adjunct professors provide individualized coaching, based on the Clinic II interns’ needs and interests. Prerequisite: Successful completion of Clinic I in the same clinic. The clinic is graded on a 4-tier Pass-Fail basis.

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

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

This clinic is a joint effort between USD Legal Clinics and the California State Board of Equalization (BOE). Under the supervision of an attorney from the BOE’s Taxpayers' Rights Advocate Office, students will represent clients who are appealing California Sales and Use Tax determinations (tax bills). Students will have the opportunity to gain practical legal skills including client interview and counseling, evidence gathering, preparing legal briefs, and actual negotiation with auditors and attorneys. Furthermore, when necessary, students will have the opportunity to represent clients in a litigation setting at Appeals Conferences (informal hearings) and Oral Hearings (similar to court trials).

Students must attend a mandatory orientation on Friday, June 10, 2016 at noon in WH 3C.

State Sales & Use Tax Clinic II (Michael J. Larkin)
LWGC563

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

Clinic II interns refine their skills, working on complex cases and cases already begun as Clinic I interns. Students may mentor first time clinic participants, serve as lead attorney on cases, and have additional opportunities to appear in court or administrative proceedings. Supervising attorneys/adjunct professors provide individualized coaching, based on the Clinic II interns’ needs and interests. Prerequisite: Successful completion of Clinic I in the same clinic. The clinic is graded on a 4-tier Pass-Fail basis.

Veterans Clinic II (Robert F. Muth)
LWVL581

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

Clinic II interns refine their skills, working on complex cases and cases already begun as Clinic I interns. Students may mentor first time clinic participants, serve as lead attorney on cases, and have additional opportunities to appear in court or administrative proceedings. Supervising attorneys/adjunct professors provide individualized coaching, based on the Clinic II interns’ needs and interests. Prerequisite: Successful completion of Clinic I in the same clinic. The clinic is graded on a 4-tier Pass-Fail basis.

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