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Federal Taxation Practice and Procedure (14th Edition)

Format: Print Book
Product ID: 10010285-0006
ISBN: 9780808058274
Provides a clear explanation of the organization, structure and processes involved in IRS practice.

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Federal Taxation Practice and Procedure (14th 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 new 14th 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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More Information
Contributors Robert J. Misey
Product Type Publications
ISBN 9780808058274
Format Print Book
Robert J.  Misey
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.