USA - ASIA- MIDDLE EAST - NEW YORK - MIAMI - LA - HONG KONG - DUBAI - INDONESIA - MALAYSIA - EUROPEAN UNION - SINGAPORE - BEIJING
for Civil Tax Procedure
I. COURSE DESCRIPTION
Civil Tax Procedure addresses the structure of the
US tax system; the IRS and other tax collection and enforcement
agencies; administrative and judicial tribunals with jurisdiction;
dealing with audits; administrative rulings; assessment
of deficiencies and penalties; closing agreements; tax liens;
statutes of limitation; claims for refund; hearings before
the IRS Appeals Office, and civil and criminal aspects of
tax fraud; ethical issues in engagement acceptance; confidentiality
and the attorney-client evidentiary privilege; conflicts
of interest; and tax shelters.
This course is taught by Larry Fedro, retired after
37 years of service with the IRS including serving as a
national coordinator of Tax Shelters; and Robert Bloink
who entered into private practice in 2001 after eight years
with the IRS’ General Counsel office.
Civil Tax Procedure is an LLM executive level course. Credit for this course may not be applied to the JD degree
course will be taught at the executive level and will employ
case studies beyond IRC analysis.
for US track
This course will involve fourteen weekly modules
that are delivered through on-line instruction pursuant
to current program specifications.
Each module will contain text material, study guide
instruction, and weekly interactive participation.
Text material may contain a combination of code sections,
cases, and commentary materials.
Study guides will contain commentary materials upon
the text materials with imbedded exercises and assignments
to be completed either independently or within a group of
two to five persons.
Assignments may be submitted directly to the Instructor
or submitted to the classroom.
Each module, selected students may be called upon to deliver
answers in the Internet based classroom to questions posed
by the instructor.
Questions may be posed in case study form or in issue
may be short (one page) form or long form (five page analysis).
During the semester, module based audio and videotape lecture
construction will be explored as well as the provision to
students through streaming technology.
During the sixteen-week semester, the students will
have two technology skills and control weeks.
The first week of the course, the student will spend
the time acquiring and testing the necessary accessing components
of the course, including: blackboard skills, database access,
proxy server access, material download, and other technical
students will introduce themselves and identify with each
other (camaraderie and network building).
During the third week, students will be given another
breather week to check the quality of their acquired technology
technical skills and offsite database access in order to
identify any problem areas that require immediate correcting.
During the semester, each student will receive at
least two detailed feedback sessions from the Instructor
through the detailed marking of his/her/group study guide
assignments and/or class participation.
Separately, the Instructor is available for office
hour private counseling through email, telephone, and by
residential office appointment.
Other assignments may receive feedback and will receive
a grade, recorded in the online grade book that students
may assess their performance.
IV. ATTENDANCE AND PARTICIPATION
This online course requires attendance which is measured by
(1) the modular-weekly interactive participation opportunities
in the classroom, (2) mandatory weekly participation through
being called upon to address the class for certain modules
as well as (3) modular study guide assignments.
Missing mandatory weekly participation assignments
is the equivalent of being not prepared in class and will
result in a zero for that assignment.
Not turning in study guide assignments will result
in a zero for that assignment.
V. EVALUATION OF STUDENT
Grades will be determined through a combination of
factors, as follows:
exam – 50%;
study guide assignments – 25%
participation – 25%
VI. REQUIRED TEXTS
texts edited and authored by the Instructor, supplemented
by reference materials.
Reference materials will include source materials
and secondary materials.
is conducted using the Internet WWW as well as, and most
importantly, value added databases, such as
US and foreign materials; Tax Treaties
US and foreign materials; especially the country by
country tax materials
International databases jurisdiction by jurisdiction,
and its global treatises
UK and international materials, especially Commonwealth/Caribbean
especially Canadian and Commonwealth/Caribbean case
especially the treatises that explain planning techniques
by topics, such as estate planning, for jurisdictions
US and foreign materials
Analysts, especially its superior tax treaty database,
foreign law and global tax update magazines
Law Publishers - all foreign statues in English
and PhD thesis and dissertation databases
tax research using databases such as Hein and CCH
other databases that we subscribe to for you (see the
external links in the classroom for details).
the student should use the electronic book libraries and
research the titles available. Finally, the student
is encouraged to use the university library or another library
through a University library exchange program.
The IRS as an Administrative Agency
Statements of IRS Position and Practice
Statute of Limitations
Civil Penalties, Part I
Civil Tax Penalties, Part II
The Examination Function
The Appeals Function
Overpayment, Refund, Credit and Abatement
The Service’s Investigatory Powers
The Tax Collection Function:
Tax Liens and Levies
Online Course Requirements for AAFM Financial Board Certification:
Chartered Wealth Manager - Take LLM 131, and LLM200
Chartered Trust & Estate Planner - Take: LLM111 and
Chartered Portfolio Manager - Take LLM 222
Chartered Risk Manager - Take LLM106 and 110
- Chartered Asset Manager - Take LLM 104 and LLM 105
- Chartered Market Analyst - Take LLM 333 (Must of Masters
Degree, JD or CPA)
- Registered Financial Specialist - LLM 101 and LLM 102