This comprehensive course provides participants with in-depth knowledge of tax dispute resolution mechanisms, appeals processes, and litigation strategies. Participants will learn how to navigate complex tax controversies from initial audit through appellate procedures and courtroom litigation. The course covers both administrative and judicial remedies available to taxpayers, focusing on practical strategies for achieving favorable outcomes. Through real-world case studies and simulated exercises, attendees will develop the skills needed to effectively represent clients or organizations in tax disputes.
Tax Dispute Resolution, Appeals, and Litigation
Tax and Revenue Management
October 25, 2025
Introduction
Objectives
Upon completion, participants will be able to:
- Understand the complete tax dispute resolution lifecycle
- Develop effective audit defense strategies
- Prepare and file administrative appeals
- Navigate tax court procedures and rules
- Draft persuasive protest letters and legal memoranda
- Manage discovery and evidence in tax litigation
- Negotiate settlements with tax authorities
- Understand alternative dispute resolution options
- Evaluate litigation risks and costs
Target Audience
- Tax attorneys and legal practitioners
- Corporate tax directors and managers
- Tax controversy specialists
- Accounting firm partners and managers
- Government tax officials
- In-house counsel for multinational corporations
- Tax consultants and advisors
- Financial controllers
Methodology
- Case studies of landmark tax disputes
- Simulated audit and appeals exercises
- Role-playing negotiation scenarios
- Document drafting workshops
- Group discussions of ethical dilemmas
- Individual research assignments
- Mock trial simulations
- Expert guest speaker sessions
Personal Impact
- Enhanced negotiation and advocacy skills
- Improved strategic thinking abilities
- Increased confidence in handling complex disputes
- Expanded professional network
- Career advancement opportunities
- Specialized expertise in tax controversy
Organizational Impact
- Reduced tax liabilities through effective dispute resolution
- Improved compliance and risk management
- Enhanced reputation with tax authorities
- Cost savings through efficient dispute management
- Strengthened internal controls and processes
- Better decision-making in tax positions
Course Outline
Understanding Tax Dispute Framework
Tax Authority Powers and Procedures- Statutory authority and limitations
- Audit selection criteria and processes
- Information gathering powers
- Taxpayer rights and obligations
- Record keeping requirements
- Responding to information requests
- Managing tax authority relationships
- Informal dispute resolution techniques
- Documentation and evidence preparation
Administrative Appeals Process
Preparing Administrative Appeals- Protest letter drafting techniques
- Legal argument development
- Supporting documentation organization
- Statutory deadlines and requirements
- Negotiation tactics and approaches
- Settlement evaluation frameworks
- Risk assessment methodologies
- Authority delegation and limitations
Litigation Preparation and Strategy
Pre-trial Procedures- Jurisdictional considerations
- Pleadings and motions practice
- Discovery planning and management
- Expert witness selection and preparation
- Evidence rules and applications
- Witness examination strategies
- Exhibit preparation and presentation
- Trial notebook organization
Court Procedures and Tactics
Tax Court Litigation- Small case procedures
- Regular case procedures
- Motion practice strategies
- Settlement conference techniques
- District court procedures
- Court of Federal Claims
- Bankruptcy court considerations
- Appellate court strategies
Alternative Dispute Resolution
Mediation and Arbitration- Voluntary disclosure programs
- Fast-track settlement procedures
- Mediation techniques and benefits
- Binding arbitration considerations
- Cost-benefit analysis frameworks
- Settlement negotiation tactics
- Closing agreement requirements
- Future tax period implications
Specialized Tax Controversies
International Tax Disputes- Transfer pricing controversies
- Treaty application disputes
- Foreign account compliance issues
- Cross-border collection matters
- Reasonable cause defenses
- First-time abatement procedures
- Accuracy-related penalties
- Fraud and negligence defenses
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