UH Law Tax Procedure Class General Information - Fall 2015

Federal Tax Procedure Class
UH Law School
Fall 2015


  1. Class Assignments:  here.  There may be revisions to the assignments 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 - JOHN A. TOWNSEND, FEDERAL TAX PROCEDURE - STUDENT EDITION (2015), here
  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: [to come]  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 I ask you something about a form on the exam, I will provide a copy of the form with the examination.  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.  But, you should read the forms as we encounter them in the classes.  You will then be prepared to use your time more effectively in the examination
  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.  If for some reason you cannot get the form to return by email via the submission dialog in the upper right, just send the information in an email to jack@tjtaxlaw.com.
  8. For substantive updates for the Class click the link UH TPC 2015,  here,  I recommend checking the materials in this link periodically.
  9. For errata for the book, see the Errata Page in right column - the link is [to come]
  10. The text (non-footnoted version for class) is 582 pages (2015 version, with Appendices).  The text will thus be, on average, just under 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 version of the text which I do not recommend).  I expect students to read and understand the key Code Sections.  The Code Sections may add an additional 5-10 pages per class (probably significantly less).  I 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 [to come]..
  11. Prior Examinations: here [to come]]
  12. Contact information: Jack Townsend: jack@tjtaxlaw.com; Tel: 713-521-9977 (Office)
Professor Townsend offers on SSRN a footnoted version of the text for this class titled JOHN A. TOWNSEND, FEDERAL TAX PROCEDURE - PRACTITIONER EDITION.  The Practitioner Edition (footnoted) 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 Practitioner Edition 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.