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An Introduction to Federal Tax Controversies: Audit through Litigation

(1k+ reviews)

Produced on December 05, 2019

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Course Information

Time 1h 7m
Difficulty Beginner
Topics covered in this course: Tax

Course Description

Despite its reputation as one of the world’s most complex bureaucracies, the IRS must comply with certain procedural rules and afford every taxpayer the right to dispute an IRS determination. It is possible to fight the IRS if you know what to expect and are familiar with the rules of the game. During this program, Richard Nessler of Winston & Strawn LLP will explore the stages of a typical tax controversy from examination through litigation. This program will cover the IRS audit process, including IRS document requests, administrative summonses, summons enforcement and maintaining privilege. Mr. Nessler will also explore the IRS Appeals process, collection alternatives, as well as tax litigation procedures unique to the United States Tax Court, and tax refund litigation in the U.S. District Courts and U.S. Court of Federal Claims.

Learning Objectives:

  1. Provide a fundamental overview of practice before the IRS and procedures involved in tax controversies at the administrative level through civil court litigation
  2. Examine the taxpayer’s obligation to maintain records and burden of proof
  3. Review rules of tax procedure related to IRS fact gathering and ways to protect privileged communications
  4. Explain the role of an IRS Appeals Officer and the new IRS Appeals procedures
  5. Explore the importance of venue selection in choosing the proper court to decide your federal tax dispute

Credit Information

After completing this course, Lawline will report your attendance information to {{ accredMasterState.state.name }}. Please ensure your license number is filled out in your profile to ensure timely reporting. For more information, see our {{ accredMasterState.state.name }} CLE Requirements page . After completing this course, {{ accredMasterState.state.name }} attorneys self-report their attendance and CLE compliance. For more information on how to report your CLE courses, see our {{ accredMasterState.state.name }} CLE Requirements FAQ .


Richard A. Nessler

Winston & Strawn LLP

Richard Nessler is of Counsel at Winston & Strawn LLP.  He is an experienced tax controversy litigator with 20 years of experience representing multinational corporations and individuals in a broad array of complex federal tax controversy matters and internal and governmental investigations.  His practice also includes the representation of clients in New York State tax controversy matters, as well as white collar investigations and related tax and appellate matters. 

He is a frequent lecturer and writer on tax controversy and litigation issues and is a contributing editor for Winston & Strawn’s tax controversy newsletter.  He also served as a Director of the New York University School of Law tax clinic and is a former law clerk to Honorable Joseph W. Bellacosa, Senior Associate Judge of the New York Court of Appeals.


Michael B.

Good course.

Hirobumi A.

Quite helpful information.

John B.

very informative. Great course

Kym T.

The class overview said this would qualify for California Bar ethics, but after finishing it stated the credit is for general not ethics.

Russell B.

This was an outstanding and very informative presentation of IRS plans and procedures to enable the Taxpayer to resolve a Tax Deficiency with efficiency.

Corneliu M.

An incredible presentation! Very clear, well-balanced and highly structured. This should be required viewing before and after any tax course in law school.

Mark K.

Great primer or refresher for those of us not necessarily practicing in tax law, but who may have issues come up in our practice.

Vasiliki N.

Helpful outline and basic ideas


Course presenter was well organized and clear as were slides, which is extremely helpful and appreciated.

Kathryn D.

As a non-tax lawyer, this was well delivered content that was easily digestible. Thank you.

David H.

I found the course to be very informative.

William T.

Good for a non specialist.

Anne M.

I found this presentation to be excellent as I have a client who stated to me that he has a settlement with the IRS that he is pleased with.

Charles T.

Good overview of basic tax practice.

Ennis W.

Extremely well done. Thank you.

Joseph M.

Good comprehensive summary

Sanjay B.

Great presenter.

Michael K.

Slides and simple approach/overview were very good introduction to process, procedures and options

Letcher E.

Very informative and straight forward.

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