Federal Taxation Practice and Procedure (12th 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 12th 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 FOR EDUCATORS/TRAINERS: End-of-chapter questions present practical problems, and are designed to help the student determine what to do in the situations presented. An Instructor's Manual, which is also available to adopting instructors, suggests assignments of portions of the procedural rules, as well as code sections relevant to each chapter. Chapter questions are also discussed in the Instructor's Manual. ABOUT THE AUTHOR: Robert J. Misey, Jr., J.D., M.B.A., LL.M., is a shareholder with the law firm of Reinhart Boerner VanDeurens.c. in Milwaukee, Wisconsin. Mr.Misey concentrates his practice in the areas of tax controversies and international taxation. He previously worked as an attorney with the IRS Chief Counsel (International) in Washington, D.C. and as a large-case attorney in the Western and Southeast Regions. He has tried 23 cases before the U.S. Tax Court. Mr.Misey received his Master of Laws degree, with high distinction, from Georgetown University, where he was the graduate student editor of The Tax Lawyer, and received his Juris Doctor and Master of Business Administration degrees from Vanderbilt University. He is a member of the Tax Section of the District of Columbia, California, and Wisconsin bars and a former member of the Inn of Court at the U.S. Tax Court in Washington, D.C. Mr.Misey often speaks on taxation at continuing education programs and has written numerous articles. He also teaches in the Master of Taxation program in the 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 Wolters Kluwer business.
