Prerequisite: Federal Income Tax at the JD level (or equivalent knowledge)

This course covers an advanced review of the inclusions, and exclusions, from gross income and of deductions therefrom in arriving at taxable income. The taxation of individuals will be stressed. Various doctrines, such as deferred compensation, assignment of income and step-transaction, will be analyzed. Characterization of transactions as capital or ordinary and the federal income tax consequences arising from sales, exchanges, and other dispositions of property will be covered in depth.

This course entails a study of jurisdictional and procedural problems arising in civil tax practice. This course deals with procedure and documents necessary at all stages of the controversy before the IRS, the choice of courts, pleadings and procedure for the Tax Court, the District Court, and the United States Court of Federal Claims. Statutes of limitations, penalties, examinations, administrative appeals and tax court procedure will be covered. Collection issues include offers in compromise, innocent spouse defenses, and IRS liens and levies. The burgeoning area of administrative tax practice will be studied in detail. The content of this course will be at least two-thirds civil procedure and at most one-third criminal procedure. This course also covers substantive and procedural federal criminal law in the tax and white-collar areas in the context of effective representation and professional responsibility.

This is the first of two separate courses relating to the taxation of corporations and their shareholders. These courses focus on corporations governed by subchapter C, as distinguished from other forms of doing business such as partnerships and S corporations. This course will cover the organization of a C corporation, the distinction between debt and equity, distributions (including redemptions, stock distributions and related company stock sales treated as distributions), and various other related issues. Detailed analysis will be given to corporation liquidations and to the allocation rules for income and deductions among taxpayers.

This course is a survey course that will cover the material presented in Corporate Taxation I-Il on a less intensive basis. It is directed to those students who intend to specialize in areas other than corporate taxation, yet at the same time wish to learn the broad fundamentals of corporate taxation. Students who have taken Corporate Taxation I or II will only be eligible to take this course with the permission of the director.

This course is the second course of a two-course series in corporate taxation. An in-depth study will be made of corporate reorganizations under Section 368 of the Code, including both stock and asset acquisitions, as well as corporate separations under Section 355. Also to be addressed are issues related to affiliated corporations, and the survival and transfer of corporate attributes. Problem sets will be handed out to illustrate the workings of these highly technical rules, but the course will go beyond the technical to emphasize tax planning considerations.

This course consists of a comprehensive survey of the principles and procedures of federal estate, gift, and generation-skipping taxation, including the relevant principles of valuation, the concept of complete vs. incomplete gifts, the reciprocal trust doctrine, the taxability of property owned by a decedent, life insurance, annuities, death benefits under retirement plans, joint property, powers of appointment, and transfers with retained income and reversionary interests. The course also includes a thorough analysis of the various deductions, credits, and exclusions available for transfer tax purposes.

This course will examine in-depth the provisions of Subchapter K of the Internal Revenue Code of 1 986, as amended. Included will be a study of when a partnership exists, the essential characteristics that distinguish partnerships from corporations and the difference and similarities between partnerships and S corporations. This course will also cover the partnership-like tax treatment of limited liability companies. Basic partnership tax law, including the tax consequences relating to the formation, operating and termination of partnerships and transfers of partnership interests will be analyzed in detail. Time will also be spent examining the subjects of partnership allocations, transactions between a partner and the partnership, and the treatment of partnership liabilities.

This course acquaints students with the large amount of research materials available in the tax and employee benefits areas and develop their skills in researching issues through the effective use of these materials. Primary and secondary sources will be examined in-depth. Emphasis will be placed on researching judicial decisions, legislative histories, and administrative rulings. The course will also develop skills in using computerized research skills. No final examination will be given. Student evaluations will be based on various research and writing assignments. 

The current requirements for the paper can be found by clicking HERE. Please contact Professor Kennedy with any questions (sooner is better than later)

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