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Federal Taxation Practice and Procedure (13th Edition)

Federal Taxation Practice and Procedure (13th Edition)

  • Author:
  • Publisher: CCH U.S.
  • ISBN: 9780808052517
  • Published In: August 2019
  • Format: Hardback , 1000 pages
  • Jurisdiction: U.S. ? Disclaimer:
    Countri(es) stated herein are used as reference only

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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 new 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.

    CONTENTS:

    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
    • Robert J. Misey, JR., J.D., M.B.A., LL.M., is a shareholder with the law firm ofReinhart Boerner Van Deuren s.c. in Milwaukee, Wisconsin. Mr. Misey concentrateshis practice in the areas of tax controversies and international taxation. Hepreviously worked as an attorney with the IRS Chief Counsel (International) inWashington, D.C. and as a large-case attorney in the Western and SoutheastRegions. He has tried 23 cases before the U.S. Tax Court.

      Mr. Misey received his Master of Laws degree, with high distinction, fromGeorgetown University, where he was the graduate student editor of The TaxLawyer, and received his Juris Doctor and Master of Business Administrationdegrees from Vanderbilt University. He is a member of the Tax Section of theDistrict of Columbia, California, and Wisconsin bars and a former member of theInn of Court at the U.S. Tax Court in Washington, D.C.

      Mr. Misey often speaks on taxation at continuing education programs and haswritten numerous articles. He also teaches in the Master of Taxation program inthe University of Wisconsin system. He is a co-author of a Practical Guide to U.S.Taxation of International Transactions, which is published by CCH, a WoltersKluwer business.

     

    • William T. Lundeen, C.P.A., J.D., LL.M., has served in tax positions in allthree branches of the federal government as well as in the private sector and instate government.

      While on the staff of a Senate Finance Committee member, Mr. Lundeenworked on matters related to the Economic Recovery Tax Act of 1981. Aftergraduating from the University of Virginia School of Law in 1984, where heserved as an Articles Editor of The Virginia Tax Review, he practiced tax law inNew York City with a Wall Street boutique firm, Everett, Johnson & Breckinridge.There, he worked on matters such as corporate reorganizations and Eurobondfinancing. Upon graduation from New York University School of Law with anLL.M. in Taxation in 1988, Mr. Lundeen was appointed an Attorney-Advisor atthe United States Tax Court where he served for two years. Thereafter, Mr.Lundeen served from 1990 to 1995 as an attorney within the Office of AssociateChief Counsel (International) where, first, he worked extensively on Subpart Fmatters and, then, on foreign currency issues including a win in a case of firstimpression involving IRC Sec. 988. In his last assignment within the ChiefCounsel’s Office, Mr. Lundeen led teams that negotiated Advance Pricing Agreementswith financial institutions that engaged in continual global trading ofderivatives.

      From the Internal Revenue Service, Mr. Lundeen accepted an appointment as theGeneral Counsel of the State of Illinois Department of Revenue. From 1995 to1999 he was responsible for the all legal aspects of the Department’s mission. Mr.Lundeen re-entered the private sector in 1999 and served as a partner in aregional and then in a Big Four accounting firm where he led the Midwestern taxcontroversy and risk management services practice. Currently, Mr. Lundeenserves as a Competent Authority Analyst in the Internal Revenue Service’s Officeof Tax Treaty. Mr. Lundeen authored his contributions to the 10th Edition ofFederal Tax Practice and Procedure prior to assuming his current role with the IRS.

     

    • Michael G. Goller, J.D., is the Department Chair of Reinhart Boerner VanDeuren’s federal Tax Controversy Department. He focuses on tax controversyand tax litigation as well as tax planning. His clients range from large publiccorporations to mid sized, privately-held businesses and their owners. Michaelworks on behalf of his clients in disputes with the Internal Revenue Service,Department of Justice and various other taxing authorities. He represents hisclients before the United States Tax Court, various Federal District courts, theUnited States Court of Federal Claims and the Seventh Circuit Court of Appeals.An experienced tax attorney and tax litigator, Michael helps his clientsnavigate the challenges of complex federal and state tax audits, disputes, administrativeappeals, trials, and subsequent appeals. He has an impressive trackrecord of both trying cases and negotiating favorable settlements for his clientsbefore trial.

      Michael regularly shares and deepens his expertise as a tax litigator throughprofessional speaking and writing. He frequently speaks to professional andbusiness audiences and organizations on issues of tax controversy, tax litigationand tax planning. He is listed in the Best Lawyers in America and MilwaukeeSuper Lawyers.

      Michael is a faculty member at the University of Wisconsin Milwaukee’sSchool of Business where he teaches Tax Practice and Procedure in the GraduateTax Program. He is consistently evaluated by his students as one of the BusinessSchool’s top teachers.

      Michael received his undergraduate degree in accounting and his law degree,cum laude, from Marquette University.

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