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SITE DESCRIPTION

The Office of Chief Counsel represents the Commissioner of the Internal Revenue Service (IRS) in the United States Tax Court, provides legal opinions and advice in a wide range of matters arising under the Internal Revenue Code (I.R.C.), and makes formal recommendations to the Department of Justice concerning suits filed by and against the IRS. The externship permits law students to work for the Office under the supervision of experienced tax attorneys, which serves not only to prepare externs for a career in the field of tax law, but also provides an excellent view of what the practice of law is like at the Office of Chief Counsel.

The Special Trial Attorneys of the Large and Mid-Sized Business (LMSB) Division conduct litigation practice before U.S. Tax Court and provide legal advice on the most complex and difficult tax matters assigned to the LMSB Division, an industry-focused organization with an emphasis on global tax administration for corporations and partnerships with assets greater than $10 million. LMSB attorneys (whom the extern may be required to assist at times) are routinely involved in non-docketed cases in which litigation is anticipated and advise LMSB examining revenue agents on technical issues, along with additional responsibilities which include handling litigation in the U.S. Tax Court and working with the Department of Justice on refund, bankruptcy, or summons enforcement issues.

The principal objectives of the externship include practical experience related primarily to corporate and partnership tax law; development of research, writing, and drafting skills; and preparation of pleadings, discovery documents, stipulations of fact, and trial memoranda used in Tax Court cases. Assignments related to civil tax matters may further include legal research concerning evidentiary issues anticipated at trial, exhibit preparation, drafting responses to discovery, reviewing and analyzing documents produced during litigation, interviewing witnesses, drafting deposition outlines, assisting in the deposition preparation of witnesses, attending depositions and attending trial (to the extent scheduled and/or permitted).

STUDENT QUALIFICATIONS

Prerequisites: 

  • Federal Tax of Corporations 
  • Third-year students only
     

Preferences: None

ADDITIONAL REQUIREMENTS

Student must be a U.S. Citizen.