Tax Crimes and Penalties

Steven L. Walker is an Adjunct Professor at the University of San Francisco School of Law in the LLM Taxation Program.  Students in the LLM in Taxation program gain a firm grounding in all major areas of taxation and preparation for advancing or launching successful careers in tax law.  The available courses that Mr. Walker teaches are Tax Crimes and Civil Penalties, and Federal Tax Procedure/Professional Responsibility.  Updated information about the courses can be found at www.usfca.edu/law.   Below is the course description for Tax Crimes and Civil Penalties, which is taught in the Fall Semester.

Course Description:

This course is a two-credit LL.M course that covers tax crimes and civil penalties under the Internal Revenue Code. The course is designed to teach students how to handle a sensitive and complex federal tax controversy case involving penalties and crimes. The course covers the additions to the tax, accuracy-related and fraud penalties, assessable penalties, crimes until Title 26 and Title 18, the Bank Secrecy Act, and the Foreign Account Tax Compliance Act. The course is taught through homework problems that the students work each week to learn the materials.

Course Materials:

  • Robert S. Fink, Tax Controversies—Audits, Investigations, Trials, (Matthew Bender) (available on-line through LexisNexis)
  • Internal Revenue Code and Regulations
  • Internal Revenue Manual (available on-line)
  • Department of Justice Criminal Tax Manual (available on-line)

Examination and Grading:

  • Homework – 25%
  • Quizzes – 25%
  • Midterm – 25%
  • Final – 25%

Learning Modules:

  • Module 1. Federal Tax Controversies
  • Module 2. IRS Criminal Investigations and Appeals
  • Module 3. Government Information Gathering
  • Module 4. Tax Evasion
  • Module 5. Other Tax Crimes
  • Module 6. IRS Special Agent
  • Module 7. Money Laundering, Asset Forfeiture, Methods of Proof
  • Module 8. Defenses, Collateral Consequences, Plea Agreements, and Sentencing
  • Module 9. Bank Secrecy Act and Foreign Account Tax Compliance Act
  • Module 10. IRS Voluntary Disclosures
  • Module 11. 5th Amendment and Attorney-Client Privilege
  • Module 12. Civil Penalties I
  • Module 13. Civil Penalties II