UH Law Tax Procedure Class Information

Federal Tax Procedure Class
UH Law School
Fall 2014
  1. Web site page for the class, here.  This web site has the classes and assignments.  There will be substantial revisions because the progress can't be anticipated to far in advance.  All class time slots will be filled, so if any of the later time slots are empty, that does not mean there will not be a class for the evening and will not be assignments for the evening.  They will come later.
  2. Text book download - Townsend, Federal Tax Procedure (Nonfootnoted): here.  (IMPORTANT NOTE TO STUDENTS; A REVISED VERSION WAS POSTED AS OF 8/30/14; THE ONLY REVISIONS RELATE TO PROVIDING PDF BOOKMARKS FOR THE TABLE OF CONTENTS AND MATCHING PAGE NUMBERS TO THE PDF PAGE NUMBERS FOR EASIER USE OF THE MATERIALS ON A COMPUTER).
  3. Class Materials (cases, etc.) for Class: here.  The cases that will be assigned are in these materials.  There are also examples of John Doe Summons for abusive tax shelter promoters.  Finally there is are two articles highlight practice ethics issues that we will cover.
  4. Forms for Class: here.  When we mention forms in the book, you should take a look at these forms.  I have included only the forms principally encountered in a tax practice.  Not all forms are offered, but just the ones that you might need for this class.  I think that a couple of these forms may have been updated, but the updates are not that material.  If we ask you something about a form on the exam, we will provide a copy of the form.  For example, if we ask you about the Form 872-A, Special Consent to Extend the Time to Assess Tax, we will provide the form.  And, if there is a question about the effect of the form, you likely would be able to answer the question by reading the  form.  We might ask what events terminate the consent to extend or have a question that has a fact an event that terminates the form.
  5. Internal Revenue Code.  Students should keep an internal revenue code handy and should generally review the Code section when cited in the text.  I have tried to cite in the text only the more important Code sections for the class.  (The footnoted version offers many more cites if you need them, but you will not need them for this class.)  For an online version of the Code, an excellent one is maintained by Cornell University' Legal Information Institute (LII), here.  To get to a specific code section use the general link and add a slash and the Code section.  For example, to review Code Section 6213 (a major section  in this class, enter the following link: http://www.law.cornell.edu/uscode/text/6672.
  6. Regulations and other IRS materials are not needed for this class.
  7. Student Questionnaire: here.  All students should fill out this form and return it as soon as possible.
  8. For substantive updates for the Class click the link UH TPC 2014, here.  We recommended checking the materials in this link periodically.
  9. For errata for the book, see the Errata Page in right column - the link is here.
  10. The text (non-footnoted version for class) is 579 pages (2014 version).  The text will thus be, on average, just less than 45 pages per class with 13 classes of 107 minutes each (the amount required to equal 14 2 hour class sessions).  There is more reading, however.  You should generally read the Code Sections that are cited in the text (not in the footnotes for those who may work from the footnoted versions).  We expect students to read and understand the key Code Sections.  The Code Sections may add an additional 5-10 pages per class (probably less).  We also will assign cases and articles for you to read for some classes.  The cases and articles are in the download materials above.  Cases will be assigned so that students will know in advance when they will be called upon.  The case assignments will be on the class assignment page here.
  11. Prior Examinations: 2012 and prior are here.  2013 is here.  [Note on 11/21/14 8:15am:  I just tried the 2013 link and it works for me; I asked students to try it again and, if it does not work, email me and I will send the pdf.]
  12. Contact information 
    1. Richard Husseini:  Richard.Husseini@bakerbotts.com; Tel: (713) 229-1678 (Office).
    2. Jack Townsend: jack@tjtaxlaw.com; Tel: 713-521-9977 (Office)

Professor Townsend offers on SSRN a footnoted version of the text for this class.  The footnoted version is not appropriate for this class.  However, in case any student has a need for citations or details about matters discussed in the assigned text, the footnoted version is here.

Also, for students who want to do some extra work on procedure, I highly recommend the Procedurally Taxing Blog, here.  The Procedurally Taxing Blog is written by two Villanova Law School professors and one practitioner and is the premier tax procedure blog.  I will try to link from my Federal Tax Procedure Blog the items that they post that I think should be of more immediate interest to students in this class.