Office of the Law School Registrar
Course Directory

Graduate Tax Directory
Spring 2001


ADVANCED EMPLOYEE BENEFITS TOPICS
Pamela Perdue
W77-726B sec 01 (3 hrs)
TUE 6:00 - 7:30 p.m. + SAT 10:00 - 11:30 a.m.

The course is designed to provide an overview of the rules and regulations that govern employee benefit plans including the rules of both the Department of Labor and of the Internal Revenue Service. These rules are illuminated both by the course reading, and subsequently, by the completion of real-world problems. Significant emphasis is placed on the rules that govern retirement plans that seek to be tax qualified, although other types of employee benefit plans, such as health and welfare plans, are also discussed. The class is taught at a level that takes into consideration the experience of the class members.

CORPORATE REORGANIZATIONS
Philip B. Wright
Dana A. Lasley
W77-720A sec 01 (3 hrs)
SAT 9:00 - 11:00 a.m.; WED 8:00 - 9:00 a.m.

The course focuses principally upon the tax aspects of tax-free acquisitions, dispositions and related issues. The class sessions deal primarily with the application of the Internal Revenue Code to the problems assigned for class discussion. More specifically, the course covers the following topics: (i) overview of tax-free reorganizations; (ii) acquisitive reorganizations; (iii) divisive reorganizations (spin-off transactions); (iv) recapitalization, including bankruptcy reorganizations; (v) survival and transfer of corporate tax attributes; and (vi) non divisive reorganizations and reincorporations.

CORPORATE TAX PLANNING SEMINAR
Sanford Neuman
Guy Schmitz
W77-715B sec 01 (3 hrs)
Days/Times TBA

This class/seminar is designed to provide an analysis of the application of the federal income tax corporate provisions, other than the reorganization provisions, to corporations, providing an advanced analysis of many of the topics first discussed in the basic corporate/business tax course. This course covers a corporation from inception (choice of either Subchapter C or Subchapter S; tax consequences of transferring assets to a corporation) through a corporation's life (taxation of distributions, personal holding companies, accumulated earnings tax) to the corporation's liquidation (and the tax consequences of such liquidation).

CORPORATE TAXATION
Nancy Staudt
W74-648D sec 01 (3 hrs)
TUE, THU 3:00 - 4:30 p.m.

This course involves an intensive study of the statutory, regulatory and case material governing corporate taxation. Topics covered include the tax consequences of corporate organization and capitalization, distributions to shareholders, redemptions of stock, corporate liquidations and taxable dispositions of a corporate business (both stock and asset sales). The course will be taught from a casebook and statutory pamphlet, by a combination of the case and problem methods. Federal Income Taxation is not a prerequisite for this course, but former students indicate that it is highly desirable to take Federal Income Tax before taking this course. Attendance and preparation are required and sanctions will be imposed on serious offenders.

ESTATE AND GIFT TAXATION
Edward F. Reilly
W77-713A sec 01 (3 hrs)
MON, THU 8:00 - 9:30 a.m.

An introduction to the Federal system of taxation as it pertains to wealth transfers, covering the gift, estate and generation-skipping transfer taxes. While there will be some discussion of related Federal income tax provisions and relevant state law tax provisions, the primary focus will be on Chapters 11, 12, 13 and 14 of the Internal Revenue Code of 1986, as amended. The goal of this course is to provide an overview of this system of taxation and its application to current estate planning and related transactions, with the hope that this introduction will prove useful in subsequent courses in estate planning. While some familiarity with the Internal Revenue Code will be helpful, it is not mandatory. Similarly, prior study in the law of Future Interests, Trusts and Estates, and Property would be helpful but is not a prerequisite. The class will be taught from a text (to be determined), but will also utilize occasional handout materials.

ESTATE PLANNING AND DRAFTING
Lawrence Brody
W74-628A sec 01 (3 hrs)
WED 4:30 - 6:00 p.m. + FRI 8:30 - 10:00 a.m.
Enrollment limit: 20

As the name indicates, this is an applied estate planning course where students will have the chance to use a computerized drafting system to draft all or a portion of the various legal documents used in the estate planning process, including a simple will, a marital will, a revocable trust, a revocable insurance trust, an irrevocable insurance trust, an irrevocable inter vivos trust, a durable power of attorney, and a living will. In addition, the course involves consideration of a number of sophisticated planning situations and an understanding of the transfer tax provisions of the Internal Revenue Code and Regulations, as well as techniques necessary for the acquisition of a moderate level of expertise in the field. Class time will be devoted to a discussion of the planning techniques; some non-class time will be devoted to watching videotapes on how to use the drafting system and its use to draft documents. A small portion of the grade in the course will be based on the drafting assignments and student participation in class meetings; the majority of the grade will be based on a final examination (focusing on the planning concepts discussed in class). Attendance and preparation are expected and lack thereof is likely to have an adverse effect on the "participation" portion of the grade and on what the examination will cover. Readings for each class hour will be rather substantial because of the advanced level of the course and may, on occasion, be as much as 30 or 40 pages. In addition, students are expected to make considerable use of estate planning form books, which can be found in the library. Pre/corequisite: Estate & Gift Taxation. Trust & Estates, while not required, would provide useful background information.

ESTATE PLANNING SEMINAR
Bennett S. Keller
Scott Malin
Gene Zafft
W77-703 sec 01 (3 hrs)
TUE, THU 4:00 - 5:30 p.m.

This course deals with the tax, legal and financial issues in the following areas of estate planning: the use of life insurance, including revocable and irrevocable life insurance trusts; the use and "misuse" of the marital deduction including the analysis of different formulae clauses; the use of shareholder buy-sell agreements and the valuation of closely held business interests; redemption of stock from shareholders of closely held corporations; and the use of installment payments of estate tax liability. The focus is on avoiding the pitfalls and finding practical solutions to meet clients' needs.

FEDERAL INCOME TAX
Nancy Staudt
W74-549J sec 01 (4 hrs)
MON, TUE, WED, THU 9:00 - 10:00 a.m.

An introduction to the basic principles of the federal personal income tax. Topics treated will include federal tax procedure, the definition of gross income, and exclusions and deductions from gross income. The course is designed to equip students to handle common personal income tax problems likely to arise in general practice. The course emphasizes a critical examination of the provisions of the Internal Revenue code and the Treasury Regulations so that students may become proficient in the use of these basic tax tools. The teaching methods and materials used in the course are intended to encourage independent thought and critical analysis of the law and policy of federal income taxation.

INCOME TAXATION OF ESTATES AND TRUSTS

Lawrence P. Katzenstein
W77-705A sec 01 (3 hrs)
WED, FRI 4:00 - 5:30 p.m.

The course will survey subchapter J of the Internal Revenue Code, which deals with the income taxation of trusts and estates. Subjects covered will include an analysis of the concepts of fiduciary accounting income, distributable net income and taxable income, distributions in kind, terminating distributions, income in respect of a decedent and the grantor trust and separate share rules.

SEMINAR IN TAX POLICY
TBA
W77-707B sec 01 (3 hrs)
WED 9:00 a.m. - 12:00 p.m.

This course explores key underlying legal and economic tax concepts which support tax policy. The course is broad ranged in that it covers Federal, International and State and Local tax issues as well as the legislative process. Current legislative proposals are also discussed.

TAX FRAUD PROSECUTIONS
David V. Capes, Harry Charles
W77-708B sec 01 (3 hrs)
MON 4:30 - 7:30 p.m.

This course/seminar will examine how criminal tax fraud cases are investigated and prosecuted. Topics covered include a general survey of the Title 26 and Title 18 criminal statutes related to tax fraud, how to deal with revenue and special agents during the audit or investigation, IRS procedures involving evidence gathering, IRS and Department of Justice review of tax fraud cases, grand jury procedures, methods of proof and trial procedures, sentencing guidelines, and civil considerations involved in the criminal case.