IRS Looks to Tax Evidence Book as Training Resource

Professor Joni Larson authors: A Practitioner’s Guide to Tax Evidence

Professor Joni Larson
Professor Joni Larson

December 4, 2013 - Thomas M. Cooley Law School professor and assistant director of the school’s Graduate Tax Program, Joni Larson, recently published a book that has become a leading training resource for chief counsel attorneys representing the Internal Revenue Service (IRS) before the Tax Court.

A Practitioner’s Guide to Tax Evidence: A Primer on the Federal Rules of Evidence as Applied by the Tax Court began as a law review article written while Larson was litigating on behalf of the IRS. At the time, there was no resource specifically designed for Tax Court litigators and Larson responded to the need. Over the years, she updated the article to include new Tax Court cases, but when the article reached 200 pages, and had more than 1,300 footnotes, it became too large of a document to continue as a law review article. 

The book, published by the American Bar Association Section on Taxation, provides insights into the Federal Rules of Evidence as applied by the Tax Court. It guides attorneys facing evidentiary issues by providing a comprehensive summary of cases interpreting each rule.  The book also includes many practical pointers designed to assist the tax litigator.

“Having a book that focuses on the Tax Court’s rulings regarding Federal Rules of Evidence issues greatly aids the bar of that Court,” said T. Keith Fogg, professor and director of the Federal Tax Clinic at Villanova Law School. “Professor Larson’s condensed and well-organized sections allow the reader to easily spot a particular issue or the Evidentiary Rule at hand and to find the supporting cases. The brief summary of requirements of the major rules assists the practitioner in charting the proof necessary to succeed.”

Larson clerked for the U.S. Tax Court, and then joined the Office of Chief Counsel as a tax litigator in the Austin, Texas, District Counsel Office. She left government service to enter private practice, but eventually returned to government work. She spent several years with the Passthroughs and Special Industries Branch of the Field Service Division of the National Office and, after the reorganization, worked in the Small Business/Self-Employed Division. She earned her J.D. from the University of Montana and LL.M. in Taxation from the University of Florida.

“I am excited that Professor Larson’s book has become so widely accepted so quickly,” said Gina Torielli, director of Cooley’s Graduate Tax Program. Cooley Law School is honored to have Professor Larson teaching tax law and helping lead our Graduate Tax Program. Part of Cooley’s mission is to provide a practical legal education; this is done by having the most experienced attorneys in the classroom. Professor Larson’s professional experience makes her one of the leading tax law professors in the country and we are honored to have her in our classrooms.”

About Cooley Law School: Celebrating 40 years of excellence, the Thomas M. Cooley Law School is a private, nonprofit, independent law school accredited by the American Bar Association and the Higher Learning Commission. Cooley has provided its more than 17,000 graduates with the practical skills necessary for a seamless transition from academia to the real world. Cooley offers its Juris Doctor program, Joint Degree programs, and Master of Laws programs three times a year with enrollment in January, May and September. Cooley Law School has campuses across Michigan in Lansing, Auburn Hills, Grand Rapids and Ann Arbor, and in Tampa Bay, Fla.



Cooley Professor and Assistant Director of Cooley’s Graduate Tax Program Recently Published - A Practitioner’s Guide to Tax Evidence: A Primer on the Federal Rules of Evidence as Applied by the Tax Court.

Book’s Practical Pointers Help Tax Litigators and Provides Insights into the Federal Rules of Evidence.

It is a Leading Training Resource for Chief Counsel Attorneys Representing the Internal Revenue Service (IRS) Before the Tax Court.

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