Tax Ethics, Opinions and Penalties

2 Credit Hours

This course considers the ethical issues faced by advisors in structuring tax transactions, rendering opinions and resolving tax controversies with the Internal Revenue Service. These issues will be studied in the context of the relevant professional rules of legal ethics, administrative rules governing practice before the Internal Revenue Service, and statutory penalties applicable to taxpayers and preparers. Particular emphasis will be given to the interplay of these rules with the process and relevance of advising clients, including the issuance of opinions. Registration Requirements: Basic Federal Income Tax or enrollment in the Tax LLM program is a pre-requisite for this course. This course meets the Legal Ethics graduation requirement for the JD program. Method of Evaluation: Examination.