College of Law

Tax Clinic - Tax Court I

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Law 7600 - Fall 2012

Professor: Ronald W. Blasi    Class Times: M, 4:10 pm - 5:50 pm   
Syllabus: Syllabus |     Location: Room 653   
Course Management Site: Web site     Connect: Class Roll    

Course Description

Tax Law Clinic Tax Court I. Prerequisite: Law 7095 This clinic will permit students to assist individual clients to prepare their cases for presentation before the Small Claims Division of U.S. Tax Court and before the administrative appeals offices of the Internal Revenue Service. Under appropriate supervision, students will provide advice in a wide range of matters arising under the Internal Revenue Code. They will interview clients, research legal issues, analyze facts, prepare protests and petitions. This course may be taken by a limited number of students, and students seeking to enroll must have an overall GPA of 2.30.

Course materials

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Syllabus

Updated: May 20, 2014, 3:07 pm

Low-Income Taxpayer Clinic 7600 (Clinic I)
Fall  Semester 2012
Instructors: Professor Ronald W. Blasi, Mr. Willard N. Timm, Jr., Mrs. Bonnie Rich,
Class in Room 653

Class times: Saturday, August 18 (8:30 a.m. – 1 p.m.) Mondays 4:10 P.M. – 5:50 P.M. Clinic work in Room 150 Tax Clinic

Office Hours - Monday - Friday 9:00 a.m. - 5:00 p.m.
Office Phone: 404-413-9230
website: www.gsulitc.org
e-mail:  rblasi@gsu.edu

Books:  The Clinic website is the electronic textbook for this course.  The website contains guidance as to all aspects of your activities in the Clinic, including summaries of procedural and substantive tax law that you will be dealing with in the Clinic. 

CLINIC I STUDENTS 

Attendance, Class Participation, and Makeup Classes:  Attendance is required.  Excessive absences may result in exclusion from the class and/or a failing grade, at the discretion of the instructor.  Absence from more than 4 hours of class will be considered excessive.  You are expected to devote approximately 9 hours, on average, each week throughout the semester to the Clinic for a total of 126 hours. Time spent in class is applied toward that time commitment. Six of those hours must take place in the Clinic offices during normal business hours.  During the first couple of weeks of the term, you will probably have to work more than the average number of hours in order to familiarize yourself with your cases.  During the fall you are encouraged to spread your time commitment over the semester and up to December 18, 2012.

Structure and Grading:  Your grade is based on the following criteria: (a) professionalism , which includes your interaction with your clients, Internal Revenue Service personnel, fellow students and staff, appropriate dress when necessary; (b) adherence to Clinic administrative and other procedures including meeting all time sensitive deadlines; (c) quality of service you render to your clients as determined in part by the evaluations you will receive from your clients at the end of the semester; (d) accuracy and thoroughness of written documents and memoranda;  (e) progress of cases especially the submission of at least one memoranda by mid-term and one or more memoranda by the end of the extended term to your supervisor and finalization of documents for submission to the I.R.S.; (f) success in resolving cases including timely closing cases; (g) class participation and involvement in the Clinic; (h) meeting the minimum required Clinic hours; (i) proper maintenance of your electronic  (Amicus) and paper files; and (j) compliance with statutory and administrative deadlines.  Missing a statutory deadline may result in a failing grade in this course. See additional information on Clinic website relating to standards for grading.

If you have any questions or concerns relating to your progress during the term you should discuss them with Professor Blasi as soon as your questions or concerns arise.

Prerequisites:  In order to handle the issues commonly encountered in the Clinic, students must have successfully completed Basic Federal Taxation (Law 7095).

Goals and Approach:  The principal objective of the Tax Clinic is to provide you with an environment in which you learn to exercise professional judgment in a supervised setting.  You will be confronted with ethical and professionalism issues.  You also will develop the essential lawyering skills of interviewing clients, gathering and verifying facts, preparing documents that will be filed in court or with administrative agencies, etc... Considerable time will be spent drafting memoranda that will improve your writing.  Although students in the Clinic work on tax matters, the practice skills that are developed are applicable to all areas of the law.

Extra Material:  There are several books designed to help understand I.R.S. procedure.  Among them are Saltzman, IRS Practice and Procedure, published by Warren, Gorham & Lamont and Effectively Representing Your Client Before the IRS.  This is a product of the American Bar Association Section of Taxation Low Income Taxpayers and Pro Bono Committees.  There are some copies in the Clinic library.

Clinic I Classes

8/13/2012  

  • Background on Clinic
    • Formation 
    • Advisory Committee
    • Funding
    • Graduates
  • Mission:
    • Transition to Practice 
    • Professional Judgment
    • Service
  • Dispute Resolution
    • Success Achieved through collaboration
    • Relationship with IRS
  • Staff and their functions, including GRA's
    • Mr. Timm
    • Ms. Rich
    • Professor Blasi 
    • Accessibility
  • Client Confidentiality 
    • Access to Clinic and files 
    • Locker combination
    • Need for security
  • Use of offices
    • Equipment
    • Phones
    • Guests
  • Standard for grading
    • Quality of service
    • Adherence to Clinic procedures
    • Progress on cases
    • Mid-term reviews
    • Weekly meetings
  • Difference with other law school courses:
    • Confidentiality
    • Collegiality
    • No fixed assignments
    • Ingenuity
  • Electronic text book
    • Web site
  • Getting started
  • Amicus
  • Keeping time

8/18/2012 - Saturday Class

  • POA'S
  • File system
  • Keeping client informed and files documented
  • Interviewing exercise
  • Intro to substantive areas
    • Collection alternatives:  OIC, CNC, IA's
    • Petition, appeals
    • Statute of limitations
    • Audit Reconsideration
  • OIC exercise
  • Investigative tools
  • Model memo, forms, etc...
  • Flow chart

8/20/2012

  • Collection Alternatives
    • Offer in Compromise
    • Installment Agreements
    • Currently Not Collectable
    • Form 433s

8/27/2011

  • Innocent spouse relief
  • Injured Spouse Relief

9/3/2012 - No Class - Labor Day

9/10/2017

  • Transcripts

9/17/2012

  • Selected tax procedure issues
  • Statute of limitations
  • Petition and Appeals

9/24/2012

  • Managing Professional Relations

10/1/2012

  • Mid-Semester - No Class on Monday.  During this 8th week there will be mid-semester reviews with Professor Blasi, Ms. Rich and Mr. Timm

10/8/2012

  • Miscellaneous Issues

11/12/2012

  • Transitioning cases

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