Courses

    The objective of this course is to help foreign-trained lawyers improve their analytical and writing skills by examining a concrete tax problem. We begin by studying closely the provisions of the Internal Revenue Code and Treasury Regulations that relate to the problem. After the students have become familiar with the governing tax principles, we will present orally the detailed facts of the problem. Students will then prepare a “Statement of Facts,” which will eventually become the first section of a law firm memorandum or opinion letter addressing the problem. Students will receive detailed feed-back on their draft “Statement of Facts” from the standpoint of legal sufficiency and English expository writing.

The next phase of the course involves a detailed review of the judicial case law interpreting the governing Code and regulatory provisions. Students will be encouraged to approach these decisions critically, examining their consistency with each other and with the statutory and regulatory framework, as well as considering their potential application to our problem. After completing this review, students will draft a complete memorandum or opinion letter analyzing the problem in light of the governing law. Students will receive detailed feedback on their first drafts, then prepare a second draft of the memorandum or opinion letter. For the final session of the course, students will be divided into groups and will present arguments on behalf of the taxpayer and the Commissioner of Internal Revenue, respectively.