The goal of this seminar to enable students to achieve proficiency in tax research and writing—the two foundations of tax practice—at a professional level. The focus is to identify the sources of federal tax law, the different kinds of legal authority and secondary sources, weight of authority, the role of tax lawyers and tax advice in the tax system, and how and where to do tax research. The class meets four times as a group at the beginning of the course for 14–16 hours of intensive tax research training over two weekends. These sessions include hands-on training, utilize primary and secondary tax research, and legislative as well as regulatory history research. Students undertake an assigned tax research project, produce a detailed memorandum (10–15 pages) and a private letter ruling request. At least one revision of the memorandum and private letter ruling request are required. Students are permitted to continue to revise their work to improve their grade. Students meet with the professor in individual tutorial sessions as the research and writing progresses.

This upper-level writing and research course is a bridge to practice for students interested in becoming proficient in tax research and writing, the foundations of tax practice.

Satisfies the Writing Requirement.

Recommended for the following Professional Pathways: Corporate Transactions and Governance; Financial Services and Compliance; Health Care Management and Compliance; Government/Public Sector; International Business; Labor and Employment (Corporate Perspective); Real Estate and Land Use; Tax; Trusts and Estates; General Practice – Transactional

Pre/co-requisite: Federal Income Tax: Individual

2 Credits