Introduction

Tax litigation is a complex legal process that requires in-depth knowledge of tax law, administrative procedures, and litigation strategies. When taxpayers and businesses face IRS audits, tax disputes, or criminal investigations, proper legal representation is essential to protect financial interests and minimize legal exposure.

This 5-day intensive course is designed for tax attorneys, CPAs, forensic accountants, and financial professionals who need to handle tax litigation, represent clients in tax disputes, and navigate tax court procedures. Participants will engage in real-world litigation simulations, IRS dispute resolution case studies, and mock trials to develop the skills needed for successful tax litigation defense.

Course Objectives

By the end of this course, participants will be able to:

• Understand the structure of tax litigation, including U.S. Tax Court, Federal Court, and Appeals.
• Develop effective legal strategies for defending clients in IRS disputes.
• Navigate civil vs. criminal tax cases and potential penalties.
• Analyze tax fraud cases and defend clients in tax evasion lawsuits.
• Learn IRS settlement procedures, alternative dispute resolution (ADR), and tax appeals.

Who Should Attend?

This course is ideal for professionals handling tax disputes, litigation, and legal tax defense, including:

• Tax attorneys and legal advisors specializing in tax litigation.
• CPAs and Enrolled Agents (EAs) representing clients in IRS disputes.
• Forensic accountants investigating fraud and tax compliance issues.
• Corporate tax professionals and CFOs dealing with large-scale tax disputes.
• Financial consultants and advisors assisting clients in high-stakes tax cases.

Course Outline

Day 1: Fundamentals of Tax Litigation & IRS Dispute Resolution

• The tax litigation process: Administrative appeals, trial courts, and appellate courts.
• Civil vs. criminal tax cases: Understanding key legal differences.
• IRS enforcement mechanisms: Audits, liens, levies, and asset seizures.
• Statute of limitations for tax cases: Deadlines for IRS disputes and litigation.
• The role of the U.S. Tax Court, Federal Court of Claims, and District Courts.

Workshop: Analyzing a tax dispute case and choosing the best legal strategy.

Day 2: Tax Fraud, Evasion, and Criminal Tax Litigation

• Key tax fraud laws (26 U.S.C. § 7201, § 7206, and § 7212).
• IRS Criminal Investigation Division (CID) procedures.
• Defending against tax evasion, false reporting, and offshore account violations.
• IRS whistleblower cases: Risks and opportunities.
• Building a strong legal defense against criminal tax charges.

Case Study: Defending a business owner accused of tax fraud.

Day 3: Civil Tax Litigation & Taxpayer Defense Strategies

• Challenging IRS assessments and defending taxpayers in civil cases.
• Burden of proof in tax litigation: IRS vs. taxpayer responsibilities.
• Settlement procedures: Offers in Compromise (OIC) and penalty abatements.
• Navigating the IRS Office of Appeals for out-of-court resolutions.
• Taxpayer Advocate Service (TAS) and protecting taxpayer rights.

Mock Hearing: Presenting a taxpayer’s defense before a Tax Court Judge.

Day 4: International Tax Disputes and Cross-Border Litigation

• FATCA, FBAR, and international tax compliance challenges.
• OECD tax dispute mechanisms and BEPS enforcement.
• Defending against transfer pricing disputes and global tax audits.
• IRS Voluntary Disclosure Program (VDP) for offshore assets.
• Legal risks in multinational corporate tax structures.

Scenario Analysis: Resolving a cross-border tax compliance dispute.

Day 5: Tax Court Procedures, Litigation Techniques, and Mock Trial

• Trial preparation: Pre-trial motions, discovery, and evidence gathering.
• Presenting a tax case in court: Opening statements, witness examination, and closing arguments.
• Expert witness testimony in tax trials.
• IRS settlement negotiations and alternative dispute resolution (ADR).
• Final Capstone: Participants conduct a mock trial for a complex tax litigation case.

Conclusion & Certification

Participants who complete the course and pass the final assessment will receive a Certification in Tax Litigation & Legal Proceedings, demonstrating expertise in tax dispute resolution, litigation strategies, and tax court representation.

Program Benefits

• Expert-Led Training – Learn from tax attorneys, forensic accountants, and former IRS litigators.
• Hands-On Learning – Engage in mock trials, case studies, and litigation exercises.
• Legal & Compliance Focus – Master civil and criminal tax litigation strategies.
• Strategic Defense Techniques – Strengthen negotiation skills and tax court procedures.
• Career Growth – Gain an edge in corporate tax law, forensic accounting, and tax litigation defense.

Career Opportunities After Certification

• Tax Litigation Attorney – Representing clients in civil and criminal tax cases.
• IRS Dispute Consultant – Handling audit defense and tax settlements.
• Forensic Tax Accountant – Investigating tax fraud and compliance violations.
• Corporate Tax Defense Specialist – Managing tax risk for multinational companies.
• Tax Court Advocate – Representing clients in U.S. Tax Court and federal litigation.