This two CPE hour course is devoted to a detailed examination of legislative sources of authority. The discussion includes an introduction to tax authority, the legislative process, the Internal Revenue Code and evaluating and locating legislative authority.
Publication Date: May 2020
Topics Covered
- Introduction to Tax Authority
- Legislative Authority: A Historical Perspective
- The Legislative Process
- Internal Revenue Code: A Closer Look
- Evaluating and Locating Legislative Authority
- "Substantial Authority" in Tax Controversies
Learning Objectives
- Distinguish between primary and secondary tax authority
- Explain the historical development of the tax law
- Describe the legislative process for a tax bill
- Detail the organization of the Internal Revenue Code
- Differentiate substantial authority and reasonable basis in tax practice
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
Instructor
Jennifer Kowal
Jennifer Kowal, JD, has been a tax professor and the director of the graduate tax program at Loyola Law School in Los Angeles since 2003. Loyola’s graduate tax program offers an LL.M. in Taxation for attorneys and a Master in Tax Law for non-lawyers. Professor Kowal teaches courses in advanced income taxation, income tax timing issues, corporate taxation, and tax research, among others. Prior to teaching at Loyola, Professor Kowal taught in the International Tax Program at Harvard Law School.
She also practiced law with the firms of Irell & Manella in Los Angeles and Ropes & Gray in Boston, advising clients on the taxation of various business transactions, including cross-border, partnership and corporate structures. Professor Kowal holds a BS in Accounting with distinction from the University of Kansas, and a JD from UCLA School of Law, where she was a member of the Order of the Coif.