Tax Law Institute | 1717 N Street NW |STE 1 |Washington, DC 20036 | +1(202) 800-9230
U.S. Tax Court Proceedings
Pro Bono Practice
- The Tax Law Institute at Washington DC | Mock Trial Program requires CPA and EA Tax Bar applicants and newly-admitted USTCPs to prepare for pro bono practice in U.S. Tax Court. Please visit our pro bono program webpage, click here.
- Here 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 collectively with a seasoned USTCP to review documents, collect additional evidentiary information, and ensure Code compliance has been met.
- 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 for U.S. Tax Court Practice
With Access to Legal Information & Research provided by the Tax Law Institute
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:
Professor Louis B. Carpenter III CPA CFP USTCP | Tax Litigation Counsel and 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 Federal Tax Clinic Board of Directors
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
Serina Moy E.A.| Resident Scholar and Senior Lecturer in IRC at the Tax Law Institute | Faculty Advisor at the Tax Litigation Clinic | Hawai'i Federal Tax Clinic | U.S. Tax Court Clinical, Student Practice and Calendar Call Program | Alternate Director, Hawai'i Federal Tax Clinic Board of Directors
Professor Michael Stuart J.D. M.P.A. | Litigation Training and Trial Practice Director at the Tax Law Institute and Professor Emeritus | Volunteer Educational Advisor to U.S. Tax Court Clinical, Student Trial Practice and Calendar Call Program at the Hawai'i Federal Tax Clinic | President, Hawai'i Federal Tax Clinic aka Hawai'i LITC Corp.
The John F. Dean Apprenticeship for U.S. Tax Court 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.
The program covers the following seven (7) topical areas. Included in the cost are all classes, tutorial services and Mock Trials. There are no additional fees beyond the initial cost of the program.
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
Program Objective & Costs
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.
Fee: $27,995 USD
Fee: $ 4,995 USD |Self-instructing Tax Law Library Utilizing A.I.
Fee: $1,500 USD | Print Copy of Textbook
Financing Available
Questions: Email michaeljerome.stuart@aya.yale.edu | Text IQ-58894529
Facsimile of Tax Law Institute Certificate of Completion Awarded to those who complete Apprenticeshi
Self-Instructing Tax Law Library Utilizing A.I.
Purchase our self-instructing Tax Law Library that utilizes artificial intelligence to prepare for the 2025 U.S. Tax Court Bar Examination. Self-Study using the latest artificial intelligence technology. Pass the bar. Become a United States Tax Court Practitioner. Start your own Federal Tax Litigation Practice. Get all six (6) tested subjects and more - Federal Tax Procedure, IRC, Case Law, Tax Evidence, Legal Ethics & U.S. Tax Court Rules - $4995
Available January 2025