Federal Taxation Practice and Procedure (13th Edition)

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Federal Taxation Practice and Procedure (13th Edition) provides a clear explanation of the organization, structure and processes involved in IRS practice. A favorite in practice and procedure classes because of its clear descriptions and logical presentation, it is a top reference for practitioners as well. The book patiently covers the basics, the complexities and the details with plenty of real-life illustrations and examples. All the latest IRS structural changes and developments are explained, and the book helpfully includes reproductions of official letters, forms and notices used by the IRS.

This 13th Edition reflects the latest statutory, regulatory and case developments along with changes in IRS operations and processes. Included right in place are special end-of-chapter problems for those using the book as a text or training tool. The authors continue the practice of carefully and concisely explaining the workings of the IRS, so that the reader gets a clear sense of how things work on a practical level.

This comprehensive guide discusses the administrative structure of the IRS, ethical duties of the practitioner, preparer penalties, and the statute of limitations. The Service's procedure in determining, reviewing, litigating and collecting tax deficiencies is described, and the roles of all the key groups within the IRS are covered. Also included are a discussion of related criminal investigations and the use of the IRS summons. The indirect method of proof is also covered.

The book's helpful Appendix contains the key sections from the Statement of Procedural Rules adopted by the Treasury Department to govern the internal administration and functioning of the IRS.

The book reflects the substantial experience and resourcefulness of its authors in highly successful IRS practices. The book's chapters are organized in a pedagogically sound sequence for optimum teaching and superior professional reference. Chapters are as follows:

Chapter 1: Organization of the IRS
Chapter 2: Practice Before the Internal Revenue Service
Chapter 3: Ethical Responsibilities
Chapter 4: Examination of Returns
Chapter 5: Large Case Audits
Chapter 6: Investigative Authority of the Internal Revenue Service
Chapter 7: Evidentiary Privilege for Federally Authorized Tax Practitioners
Chapter 8: Partnership Audit Procedures
Chapter 9: Penalties and Interest
Chapter 10: Statute of Limitations on Assessment
Chapter 11: Access to Internal Revenue Service Information
Chapter 12: The Appeals Office
Chapter 13: Assessment Procedure
Chapter 14: The Collection Process
Chapter 15: Claims for Refund
Chapter 16: Private Rulings and Determination Letters
Chapter 17: International Tax Procedure
Chapter 18: Criminal Tax Procedure
Chapter 19: Indirect Method of Proving Income
Appendices
Case Table
Finding Lists
Topical Index

For Adopting Instructors:

Wolters Kluwer offers a complete teaching package to support adopting instructors. Instructors adopting this book receive a downloadable Instructor's Guide that includes:

A short outline of selected significant points covered in each chapter, along with a suggested list of pertinent Internal Revenue Code sections and regulations, designed to serve as an initial sketch for the instructor to prepare lecture notes
Both the discussion questions in the text and the authors’ suggested answers and
A Multiple Choice Exam with questions and answers.

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Contributors	Michael G Goller, Robert J. Misey
ISBN	9780808052517

About the author(s)

Michael G Goller

Michael G. Goller is a shareholder in Reinhart's Tax and Corporate Law Practices. His practice focuses on tax controversy, tax litigation, and tax planning. The clients Michael represents include large, public corporations, mid-sized, privately held businesses and their owners. He handles a wide variety of tax- related issues, including complex income and estate and gift tax controversies. Michael represents clients involved in disputes with the IRS, the Department of Justice, and various other taxing authorities before the United States Tax Court, various Federal district courts, the United States Court of Federal Claims, various state courts and the Seventh Circuit Court of Appeals. As an experienced tax attorney and tax litigator, Michael assists his clients in navigating the challenges associated with complex federal and state tax audits, disputes, administrative appeals, trials and subsequent appeals. Michael serves as a trusted advisor and legal strategist who is able to draw upon his vast knowledge and experience to offer unparalleled proficiency in his field, which is evidenced in his impressive track record of successfully trying cases to favorable settlements. Clients appreciate that Michael has the personality of litigator with the expertise of a tax attorney and provides legal advice from this unique intersection. Outside of his office, Michael regularly shares his expertise as a tax litigator through professional writing and speaking engagements where he addresses both professional and business audiences and organizations on a variety of tax controversy, tax litigation, and tax planning topics. Michael is also a longtime faculty member at the University of Wisconsin-Milwaukee's Lubar School of Business and teaches Tax Practice and Procedure in the Graduate Tax Program. At the end of each term, instructors are evaluated by their students. Michael is regularly the recipient of the Gold Star Teaching award - an annual honor that recognizes an outstanding teacher in the department. In addition, Michael is the founder of the Hastings Society for Economic Development, a group dedicated to the discussion of economic principles and how those principles can further the common good.

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Robert J. Misey

Rob Misey is a shareholder with the law firm of Reinhart Boerner Van Deuren s.c. and Chair of the firm's International Department. He concentrates his practice in the areas of international taxation, transfer pricing and tax controversies, and works with a wide range of clients from a variety of industries including manufacturing, service, energy, retail and entertainment. For U.S. based multinationals, Rob helps clients maximize foreign tax credits and take advantage of export benefits to reduce the client's overall effective tax rate. For foreign owned clients, he coordinates with the client's global tax minimization strategy, using repatriation techniques to minimize U.S. withholding taxes. Rob's significant transfer pricing experience allows him to assist multinational businesses with preparing documentation and negotiating Advance Pricing Agreements (APAs). He assists both U.S. and foreign investors in minimizing withholding taxes by taking advantage of applicable tax treaties and offshore corporations and trusts. Rob's previous experience includes nine years as an attorney for the IRS. While he was with the IRS, he served as an international tax attorney in its Washington, D.C. national office, where he was a member of the APA team, and a trial attorney and international tax specialist in San Jose, California and the Southeast Region. He also managed the International Tax Services group for a region of a Big Four accounting firm. Rob regularly shares his expertise and experience on international taxation with business and professional audiences at continuing education programs in numerous states and foreign countries. He has published numerous articles and is a co-author to treatises, U.S. Taxation of International Transactions and Federal Taxation Practice and Procedure, both published by CCH. Rob also teaches international taxation at the Master of Tax program in the University of Wisconsin system. Rob received his Juris Doctor and Master of Business Administration degrees from Vanderbilt University and his Master of Laws in Taxation, with high distinction, from Georgetown University, where he was the graduate student editor of The Tax Lawyer. A native of Milwaukee, Mr. Misey is licensed to practice in Wisconsin, California and the District of Columbia. His professional affiliations include membership in the Tax Section of the District of Columbia Bar Association. He is also a former Chair of the International Practice Section of the Wisconsin State Bar.

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