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Practice and Procedure in the U.S. Tax Court “An important new book [that takes] a practitioner all the way through a Tax Court case . . . providing helpful guidance whether this is one’s first or twentieth case. For working tax lawyers, it is a winning combination—practical, erudite, accessible, and helpful. This should be a priority purchase for any tax practitioner.” “Uniquely comprehensive in its approach to Tax Court litigation and a welcome resource to tax controversy practitioners, pro se litigants, tax professors and tax clinic students across the county. Professor Cords’ breadth of experience with Tax Court practice and procedure as a U.S. Tax Court clerk and tax law professor along with her extensive scholarship in the areas of tax policy, tax procedure and taxpayer rights provide unparalleled insight into Tax Court practice. This text is an invaluable resource and is recommended for anyone involved with Tax Court litigation.” When litigating a tax controversy, a taxpayer faces critical choices, starting with the decision of where to litigate—the U.S. Tax Court, U.S. district courts, or the U.S. Court of Federal Claims. The differences in procedure among these courts can be dramatic—and differences in procedure can mean differences in result. Practitioners in the U.S. district courts are familiar with the Federal Rules of Civil Procedure and the Federal Rules of Evidence. Most tax cases, however, involve petitions to the Tax Court, which has its own procedural rules applied alongside the Federal Rules of Evidence. This book is a uniquely comprehensive guide to all aspects of Tax Court practice and procedure, designed to help both the practitioner who appears frequently in the Tax Court and the newcomer with a first petition in the Tax Court. Guides you systematically and comprehensively through every step of Tax Court litigation… Written by an experienced Tax Court practitioner, this comprehensive reference guides you strategically through the entire process—from your initial decision to file in the Tax Court, through pleading, discovery, pretrial preparation, trial argument, and post-trial motions—for all types of cases including declaratory judgment, innocent spouse, employment status redeterminations, collection due process, and many more.
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