THE Tax Law Institute |1717 N Street NW |STE 1|Washington, DC 20036 |+1(202) 800-9230
U.S. Tax Court Proceedings
Pro Bono Training 2026-2027
- The Tax Law Institute at Washington DC | Mock Trial Program requires CPA and EA Tax Bar applicants and newly-admitted USTCPs to engage in pro bono practice in U.S. Tax Court. Please visit our pro bono program webpage, click here.
- This is how it all works. Please note, that in reality, the proceedings may be live (in courtroom) or remote (Zoomgov).
- The pro bono bar applicants work collectively with a seasoned USTCP to interview the low-income client to ensure s/he meets the IRS income guidelines. They then review documents, collect evidentiary information, determine Code compliance, and prepare and submit a Petition, which is then docketed in the U.S. Tax Court and sent back to the IRS independent office of Appeals for settlement re-consideration. Eventually, an Appeal's officer is assigned to the case and a hearing date is set.
- After an unsuccessful mock IRS independent appeal's hearing of a low-income client's case, the matter is sent back to the Tax Court, where the participants engage in simulated courtroom procedures and practices that lead up to the Branerton Conference, where the parties learn how to cooperate with each other while they each conduct informal discovery. The goal being to have the petitioner's representative work together with government attorneys and all the while maintain good client relations while moving the case forward to trial (or a possible opportunity for a second attempt at a pre-trial settlement at some future date).
- The pro bono bar applicants continue to work with a seasoned USTCP to review documents, collect additional evidentiary information, and ensure Code compliance has been met.
- Limited formal discovery then begins next where the litigants file their pre-trial motions along with memoranda of law, oppositions to motions requests, briefs, make request for and take depositions, interview and prepare witnesses, and participate in hearings to argue why motions should be granted or denied, as ordered by the Court.
- At mock pre-trial hearings, the parties call witnesses and engage in direct and cross-examinations and present their oral argument, just as they do at trial.
- After all motions are heard, the parties prepare for trial. The Court will issue its Standing Orders that speak to how the impending trial will proceed. Then the trial will occur; however, the parties will make every attempt to reach a settlement right up to the day of trial and during the trial itself. At anytime before the conclusion of the trial the parties may inform the judge that they have reached a consensus and are prepared to settle the case. If no consensus is reached the trial will proceed to its conclusion and the trial will end with the judge reserving his decision until the post-trial briefs are submitted and read.
- After the mock trial proceedings end, the parties write and submit their post-trial brief and join in post-trial discussions, file post-trial motions and attend to other procedural matters.
- U.S. Tax Court judges, seasoned tax litigators, and teaching faculty are then invited by the free tax clinic to discuss the proceedings and listen to feedback from the student-participants and pro bono student litigators.
The Mock Trial is our most acclaimed preparatory endeavor.
The John F. Dean Apprenticeship
Access to Legal Information & Research provided by Thomson Reuters
United States Tax Court Practitioner Defined
A United States Tax Court Practitioner aka Tax Litigation Counsel is a qualified non-attorney, typically an IRS-approved tax professional e.g. CPA or EA, who has passed a rigorous bar examination, received litigation training, and been vetted by the Court, and admitted to practice exclusively in and before the United States Tax Court. They provide attorney-equivalent representation in tax litigation. They are authorized legal practitioners when in practice before the U.S. Tax Court. They represent taxpayers - individuals, partnerships, corporations, estates and trusts - during legal proceedings held in U.S. Tax Court. Because of their highly specialized tax accounting skills, litigation training, and stringent IRS approval and practice requirements, USTCPs are often chosen by tax clients over tax attorneys to handle deficiency matters, civil fraud offenses and other complex tax controversies that migrate into U.S. Tax Court.
Transitioning from IRS Enrolled Agent or CPA to United States Tax Court Practitioner aka Tax Litigation Counsel is no easy task. You will become a bounded specialist in Federal tax procedure, IRC and trial practice - building blocks for a winning Federal Tax Litigation Practice.
In partnership with the Hawai'i Federal Tax Clinic | Approved U.S. Tax Court Clinical, Student Trial Practice and Calendar Call Program.
Coordinated by:
Chief Tax Litigation Counsel Emeritus & Adjunct Assistant Professor Louis B. Carpenter III USTCP CPA CFP | Admitted to Practice U.S. Tax Court | Tax Litigation Counsel and Adjunct Assistant Professor at the Tax Law Institute | Registered Coordinator of Approved U.S. Tax Court Clinical, Student Trial Practice and Calendar Call Program at the Hawai'i Federal Tax Clinic | Director, Hawai'i Tax Clinic Board of Directors | Educated at the University of Miami
Associate Professor James H. Chapman E.A. M.A. M.P.A.| Federal Tax Research Director and Associate Professor at the Tax Law Institute | Chairperson, Board of Directors, Hawai'i Federal Tax Clinic
Professor Emeritus Michael Jerome Stuart J.D. M.P.A. | The John F. Dean Professor of Federal Tax Litigation and U.S. Tax Court Trial Practice | Litigation Training and Trial Practice Director | Educational Coordinator for the U.S. Tax Court Clinical, Student Practice and Calendar Call Program at the Hawai'i Federal Tax Clinic on O'ahu | President of the Hawai'i Federal Tax Clinic aka Hawaii LITC Corp. | Director of the Charitable Giving Programs at the Tax Law Institute
Adjunct Research Professor Daniel Ng J.D. LL.M. | Litigation and Trial Practice Specialist | Estates, Gifts & Trusts Scholar | Member, Board of Directors, Hawai'i Federal Tax Clinic
Tax Litigation Counsel Jeffrey Thompson USTCP E.A. MBA M.A. | Admitted to Practice, U.S. Tax Court | U.S. Tax Court Apprentice & Faculty Intern| Preceptor for the U.S. Tax Court Bar Examination | Assistant Coordinator for the U.S. Tax Court Clinical, Student Practice and Calendar Call Program | Acting Clinic Director of the Hawai'i Federal Tax Clinic on O'ahu
Richard Cunha Esq. | Of Counsel | Admitted to Practice, U.S. Tax Court
The John F. Dean Apprenticeship
- Organized by Michael Jerome Stuart, Professor Emeritus at the Tax Law Institute, and first presented by Judge John F. Dean, Ret., formerly of the U.S. Tax Court Judiciary, The John F. Dean Apprenticeship is the nation's top (#1) attorney- and non-attorney USTCP program for Federal Tax Litigation and U.S. Tax Court Trial Practice.
- Traditional law school apprenticeships take a minimum of four (4) years to complete in any of the 4 states where an individual is allowed 'to read' the law under the supervision of a seasoned licensed attorney or judge. Afterwards, an individual is allowed to sit for the respective state bar examination. Whereas individuals who pass the Tax Court bar exam and then hang out their shingle to begin practice as a legal representative are in fact going into a courtroom with no formal legal training.
Study Topics
The program covers the following seven (7) topical areas. Included in the cost are all classes, tutorial services and Mock Trials. There are additional fees and charges beyond the cost of the basic course of study. Visit webpage, https://taxlawinstitute.com/, to gain awareness of the full breath and scope of this course of study and its costs.
A. Representation Before the United States Tax Court
B. Trial Documents Used in U.S. Tax Court Litigation
C. Legal Writing for United States Tax Court Practitioners
D. Mock Branerton Conference
E. Pre-Trial & Trial Practice
F. Litigation Strategies in United States Tax Court
G. Client Relations
Apprentices are required to complete Tax Bar Prep if they are not yet approved as an USTCP.
Here is a listing of the required courses:
- Orientation to the Tax Bar Examination
- FRE as Applied in the Tax Court
- Federal Tax Procedure
- IRC and Federal Taxation - Individual, Corporate, Partnerships and Estates, Gifts & Trusts
- U.S. Tax Court Rules of Practice and Procedure
- Case Law
- Legal Ethics
Program Objective & Costs
U.S. Tax Court litigation is logical. Good case preparation is the most important responsibility you will provide to your client, along with ensuring that you always maintain good relations and have their written informed consent about all matters relevant to the case. This program will prepare you to always do both, along with many other tasks that will ensure that regardless of all else, you will build a professional reputation as a competent and well-trained litigator and trial practitioner.
Fees: The total cost for the Apprenticeship + Tax Bar Prep is $64,176,20, i.e., $29,995 USD for Apprenticeship + $11,765 for Tax Bar Prep + associated fees and charges.
Please visit TLI webpage, The Apprenticeship, to learn more. Next sessions begin on May 9, 2026.
Financing Available @10% surcharge
Questions: Email michaeljerome.stuart@aya.yale.edu or telephone +1(202) 800-9230
Distinguished Research Professor Daniel Ng lectures on 'Estates, Gift & Trusts Litigation'.
Supervised Courtroom Pro Bono Apprentice Program
Begin on May 9, 2026. Train to become a pro bono authorized legal representative of low-income taxpayers. Attend remote hearings at the IRS Independent Office of Appeals. Participate in-person at Honolulu, Hawaii U.S. Tax Court proceedings. Represent clients under supervision of USTCPs and Tax Attorneys. Prepare Petitions, Agreements, Briefs, etc. Amend Petitions and negotiate Settlements. Engage in Motions Practice, write Stipulations, Summary Judgements, conduct legal research and work with Tax Attorneys, law professors, USTCPs and judges. Establish your practice or pass the Tax Bar Exam.