State Level: Tax Appeals Assistance Program (TAAP)
Through TAAP, you’ll represent clients in California income tax disputes with the state’s Franchise Tax Board. Under the guidance of attorneys from the Franchise Tax Board Taxpayer Rights Advocate’s Office, you’ll:
- Assist clients in disputes before the California Office of Tax Appeals (OTA)
- Conduct client interviews and gather evidence
- Draft legal briefs and memoranda
- Negotiate with the FTB
- Represent clients in appeals conferences and, in some cases, oral hearings before OTA judges
Federal Level: Tax Controversy and Litigation Practicum
At the federal level, you’ll assist clients with income and payroll tax controversies before the IRS. With both classroom learning and fieldwork under a tax attorney’s supervision, you’ll:
- Manage case files and deadlines
- Interview clients and witnesses to identify tax issues
- Research substantive and procedural tax law
- Draft pleadings, briefs, and memoranda
- Negotiate settlements with the IRS
- Assist in litigation when settlement isn’t possible, including in U.S. Tax Court
What advanced topics will you cover?
- Tax Court Practice: from initial pleadings and discovery to trial preparation, courtroom advocacy, and post-trial appeals
- IRS Collection Actions: levies, garnishments, liens, installment agreements, and offers in compromise
- Penalty Abatements: standards and strategies for failure-to-file, failure-to-pay, and international reporting penalties
- Innocent Spouse Relief: types of relief, evidentiary requirements, and key differences between IRS and FTB procedures
What will you learn?
- Build deep knowledge of state or federal tax procedure
- Strengthen your research, analysis, and writing skills
- Learn to explain complex tax law to clients clearly and compassionately
- Develop negotiation and advocacy skills with real consequences for clients
Faculty
Allison Wang