Write Trial Documents

​​​​​​​Bar Accredited Remote CLE Provider
All Jurisdictions

"If the matter concerns a tax deficiency, litigation and U.S. Tax Court then you should be talking to us"
Write Trial Documents for Tax Court

Teaching Faculty

IRS Approved Provider of CPE #RS7E4

Session 1, 2 & 3

Remote Conference Dates

Most Saturdays | May 7 | 2022
thru Saturday | July 23 | 2022

1 P.M. - 2:30 P.M. EST


Professor Emeritus

The Florida Bar | Accredited CLE Provider | IRS Approved CPE Provider | U.S. Tax Court Trial Practice, Litigation & Appeals

Workshop Activities

Introduction to representation, strategies, writing trial documents, and electronic filing rules. Distinctions drawn between academic writing, legal reasoning, and judicial decision-making. Overview of Appeal of Tax Court cases to the Federal Circuit Court of Appeals course for the state in which the taxpayer-client resides at the time the Tax Court petition was filed. Discussions to distinguish between Tax Court opinions and Tax Court decisions, and why the terms are not interchangeable. Explanations as to why opinions are usually issued in advance of the decision or order disposing of the case, and why the parties may only take an appeal from that decision or order disposing of the case. 


Youtube Video Courtesy of Bryan A. Garner

This manual on legal style is free with the course.
Many attorneys do not realize that judges appointed to the bench of the United States Tax Court are extremely tax savvy. Legal practitioners not familiar with the U.S. Tax Court Rules of Practice and Procedure will undoubtedly realize that they have embarked upon a fool's errand should they dare to venture into Tax Court without an understanding of how the Court conducts its business. ​​​​​​​Essential to those facts is the knowledge that Tax Court judges, like most judges, do not want to read convoluted, poorly-written trial documents. Simplicity and forthrightness should underlie all documents prepared and submitted during the course of any action put before the Court. In that regard, it would behoove attorneys and nonattorney practitioners to take note of the elements of legal style espoused in the Red Book. Bryan A. Garner summarizes his philosophy of legal writing as a belief that the best legal style is simple and direct that anyone can learn that style with hard work, that improvement requires abandoning old and meaningless conventions, that what distinguishes effective legal writers is an abiding empathy for the reader. Over the course of these next few weeks, we shall discuss the writing of Tax Court trial documents that should explain IRC code sections and tax law in the simplest of terms.​​​​​​​
  • Case Briefs
  • Petition for Redetermination
  • Designation of Place of Trial Form
  • Replies
  • Research Memos
  • IRS Forms
  • Branerton Letter from Petitioner/Respondent
  • Motions
  • Depositions
  • Rule 91 Trial Stipulation
  • Motion for Decision Under Rule 122
  • Motion to Compel Stipulation
  • Rule 70(c) Request for Copy of Own Statement
  • Rule 71 Interrogatories
  • Rule 72 Request for Production of Documents
  • Stipulation Consenting to Discovery Deposition
  • Rule 74(b) Notice of Deposition to Nonparty Witness (Individual)
  • Rule 74(b) Notice of Deposition to Nonparty Witness (Corporation)
  • Request for Trial Status Report
  • Tax Court Standing Pretrial Order
  • Stipulation of Settlement
  • Decision
  • Rules Governing Conduct During Proceedings the United States Tax Court
  • Decision After Rule 155 Computation
  • Stipulated Decision Pursuant to Settlement Agreement
  • Notice of Appeal (Tax Court)
  • Claim for Refund -- IRS Form 843
  • Claim for Refund -- IRS Form 1040X
  • Claim for Refund -- IRS Form 1120X
  • Claim for Refund -- IRS Form 8849
  • Extension of Period of Limitations for Filing Suit -- IRS Form 907
Photo: Memorandum Decisions (cannot be appealed)



Accredited CLE Provider
The Florida Bar

U.S. Tax Court Litigators.org
Continuing Legal Education Services
for United States Tax Court Trial Practice
1717 N Street, NW, Ste. 1
Washington DC 20036
Telephone +1.800.737.6134

Office Hours
Mon - Fri: 09:00 AM - 05:00 PM