This guide is written for Mercer law students who are involved in the Low Income Tax Clinic, but it will also be useful for students who are interested in tax controversy or taking the Federal Tax Procedure course.
When you are in this area of law, you may ask: "What is happening when a taxpayer receives a notice from the IRS that their tax return is being audited? What is happening when a taxpayer receives a “90-day letter,” or that the IRS has begun the collections process? What rights does the taxpayer have? How does a taxpayer challenge the findings made by the IRS on their tax return? What options for relief remain available?" All of these questions fall within the scope of federal tax procedure.
Federal tax procedure is a field controlled by interconnecting federal statutes, regulations, case law, and court rules. Figuring out which authority applies, how they interconnect, and what it means for the taxpayer can be a daunting task to those who are unfamiliar with this area. Fortunately, there are many great resources at your disposal. The purpose of this guide is to give you a starting point, with information on resources and tools that you can use to begin researching a taxpayer's issues.
This guide is organized by resource type, including information on the various helpful practice centers, necessary primary sources, online resources, and some of the procedural issues that you are likely to encounter in the Low Income Tax Clinic.
For a big-picture, general overview, please feel free to look at the Procedural Basics tab.
For tax return preparation, please navigate to the the Tax Return Preparation tab. (future project)
Having a good research strategy is going to help you save time and keep you out of unnecessary research rabbit-holes. It is particularly relevant to federal income tax procedure research because of how everything interacts. As you get more familiar with this area, you will develop your own preferences for the resources you are most comfortable with. You can use the suggested steps below to narrow in on your tax procedure issues, before you start to develop a method that works for you.