Subscriptions

Staffed by Teaching Faculty of U.S. Tax Court
Admissions & Trial Practice Programs for
Non-attorney & Attorney Federally-authorized
Tax Practitoners at the Tax Law Institute
Contact: 1.800.513.1598


"If the matter concerns Federal taxes and litigation then you should be talking to us"


Our Subscription Program addresses individual, partnership, corporate and other business formations for which quarterly or annual returns are submitted to the IRS. Our discounted hourly rates start at $295, a savings of $100. Consultation $395. Pictured here are the IRS Forms for filing quarterly and annual returns for corporations and partnerships.

Call us in confidence 1.800.513.1598
Litigation Advisory & Support Services

Attorneys & CPA/EA Non-attorney USTCPs

  • Solo attorney-practitioners or non-attorney USTCPs, CPA tax professionals, and their respective firms may subscribe to our litigation advisory or support services. Hourly rates start at $395.
  • To discuss a subscription plan for your individual practice or your firm, or to arrange a conference to discuss your needs. The consultation fee is $395


Registry for US Tax Court Case Referral

Attorneys & CPA/EA Non-Attorney USTCPs
Small "S" and Regular Cases

  • Attorneys, CPAs, EAs and USTCPs, in good standing, may register with our Referral Service to handle S- and Regualar Cases before the US Tax Court.
  • Pay annual registration fee $295.
  • We will post your name and practice area at our Website.
  • If we find a suitable case and you accept then pay $1,000 fee if a Regular case and $500 if a "S" case
  • You must register your name, bar/license number and practice area and contact information with us.
  • Consultations $395


Tax Law Institute


Dial-in Saturdays 3 p.m. t0 6 p.m. ET


  • The discussions occur as part of the Tax Law Institute's tutorial programs in Federal Tax Practice and U.S. Tax Court Trial Practice.
  • Purchase a seat for $125 that gives access to one informative and challenging weekly meeting about published opinions, tax evidence, procedural rules, ethical matters, and substantive tax issues.
  • Guest contributors include Sitting and Retired U.S. Tax Court judges, former IRS Counsel, Law Professors, Attorneys and CPA Members of the United States Tax Court Bar, former IRS Revenue Agents, IRS Special Enrolled Agents.
  • Guest contributors have also joined in mock trials that aided in the skills development of bar admissions applcants, seasoned practitioners, and those newly admitted to Practice before the U.S. Tax Court.


Advisory & Litigation Support

Partnerships & S-Corporation Taxpayers

  • For Attorneys, CPA/EA Non-attorney USTCPs servicing taxpayer-partners and S-corporate shareholders. Hourly rates start at $395.
  • Consultations $695

​​​​​​​Call 1.800.513.1598

Self-Represented (Pro Se) Taxpayer

Personal or Business-Related

  • Visit the U.S.Tax Court website for instructions on how to file a Petition.
    • http://www.ustaxcourt.gov
  • Call the Clerk of the U.S. Tax Court for help.
Call 1.202.521.0700

Recommended Tax Return Preparation
Audit Representation Services

Personal or Business-Related

  • We often receive inquiries regarding individual tax return preparation and audit representation. Please remember that income tax preparation and audit representation may be performed by any person approved by the IRS, regardless of their locality.

James H. Chapman, EA, MPA, MA
Advanced Tax Solutions
Tax Preparation Service
2019 S Loudoun St,
Winchester, VA 22601
Phone: (540) 533-9004

Janean Kong, EA
Smart Tax & Business Solutions, Inc.
500 Ala Moana Blvd, Tower 7, Suite 400
Honolulu, HI 96813
Phone: (808) 354-0208
www.smarttaxhawaii.com

Please take note of the following...

Crime-Fraud Exception to Attorney-Client Privilege

"Something you should know..."

  • To successfully defend a petitioner-taxpayer against IRS allegations of fraud, please know that the Crime-Fraud Exception to the Attorney-Client Privilege applies if:
    • the client was in the process of committing or intended to commit a crime or fraudulent act, and
    • the client communicated with the lawyer with intent to further the crime or fraud, or to cover it up.
  • Counsel must report violations to the presiding U.S. Tax Court judge in the case.
  • The crime-fraud exception can render the privilege moot when communications between an attorney and client are themselves used to further a crime, tort, or fraud. ... The crime-fraud exception also does require that the crime or fraud discussed between client and attorney be carried out to be triggered.
  • The crime-fraud exception cannot be used to pierce the attorney work-product privilege without the required showing that the work product was actually used in furtherance of the purported crime or fraud. The U.S. Court of Appeals for the Third Circuit clarified that, without more, even compelling evidence of a crime or fraud is insufficient to invoke the exception. The ruling has important ramifications for practitioners advising clients on the contours of lawful conduct.

Excerpt from the Federal Rules of Evidence

    U.S. Tax Court
    Document Writing Service

    Small "S" and Regular Cases
    • USTax Court Petition start at $295
    • US Tax Court Petition Reply start at $195
    • US Tax Court Stipulation start at $395
    • US Tax Court Motion & Reply start at $295
    • US Tax Court Memorandum start at $395
    • US Tax Court Post-Trial Motion & Reply start at $295
    • US Tax Court Post-Trial Brief start at $695
    Photo Courtesy of the US Tax Court

    Case Preparation & Evidence Collection Service



    "Get your evidence admitted into the record"

    • Our legal research staff will carefully assemble and scan your likely evidentiary documents, including
      • tax returns
      • bank statements
      • credit card statements
      • canceled checks
      • digital records
      • invoices
      • all of which could serve as exhibits at trial.
    • Our legal research staff will also search among court records of the thirteen Federal circuits (including Washington DC) for rulings that might increase the weight of your evidence offered to the Court.
    • Our our legal staff will review carefully, examiners' reports and other records the IRS turns over during discovery.
    • Our legal staff will assist in finding the precedent cases that the litigators will use to write persuasive Memoranda to bolster your case against the IRS.
    • Our legal staff will research and suggest content for the Motion in Limine to keep out damaging evidence against you, or prepare deposition questions and interrogatories, all under the direction of Counsel.
    • Our legal research staff will review the evidence received and write persuasively so that post-trial motion(s) are granted and post-trial brief is effective. Hourly rates, start at $395.
    • Consultations $395


    Forensic Analysis

    Performed by CPA Members of the U.S. Tax Court Bar

    We perform forensic analysis in cases where Counsel for the Commissioner alleges fraud in its Answer to the Petition. In no way, in whole or in part, will we assist in the perpetration of a client's fraud upon the Court.
    • Should you have an interest in using our Pre-Trial Forensic Services as it relates to your client's tax matters then you should call us to discuss in confidence the scope of your needs.
    • Arrangements will be made to secured live or virtual setting to discuss and review the Government facts and evidence that underlie its case against your client, and the possible steps you can take to quickly resolve the matter through admissions, settlement, or on motion, with minimal penalties.
    • Our investigative team is led by a retired U.S. Tax Court judge, CPA forensic analysts and members of the U.S. Tax Court Bar, and a Law Professor Emeritus.
    • Hourly rates start at $395.
    • Consultations $395.

    Call 1.800.513.1598

    Pass U.S. Tax Court Non-attorney Exam in 2020

    Earn $60,000 - $120,000 More as an EA, CPA, or Attorney

    Tax Law Institute
    Judicial Bar Review

    Dial-in 2020 Pre-exam Sessions
    Winter, Spring & Fall 2020

    Live November 2020
    Washington DC

    5-Day Pre-exam Review
    to prepare for the
    U.S. Tax Court Non-attorney Exam


    Call 1.800.513.1598

    United States Tax Court Practitioner
    Defined & Demystified

    Courtesy of the Tax Law Institute

    "USTCP" is the professional designation for an individual who has been examined and "admitted to practice" as an United States Tax Court Practitioner and is deemed to be a "Member of the Bar of the United States Tax Court." They may act as "Counsel" to U.S. taxpayers and foreign citizens who have received  tax deficiency or liability notices from the IRS. Specifically, an USTCP is an individual who has:
    • passed the United States Tax Court Non-attorney Bar Admissions Examination
    • been certified and "admitted to practice" by the United States Tax Court Office of Admission
    • who has been investigated and approved as a person "to be of good moral character" by the FBI

    Tax Law Institute

    Dial-in or Live Option

    2020 Litigation & Apprenticeship Program
    for 2020 Fall Opening Session of the
    U.S. Tax Court

    Moderated by US Tax Court judge

    Litigation of IRS Controversies in U.S. Tax Court
    includes Trial Documents Preparation Program

    Spring and Fall 2020

    Call 1.800.513.1598