Loyola University Chicago

School of Law

Federal Tax Clinic Client Services Offered

Student staff attorney, reaching for a client's file

The Clinic provides all necessary services to completely resolve an individual's federal tax problem. The Clinic's services are split into two regimes.

Pre-Assessment Cases

In pre-assessment situations, the clinic is generally involved in contesting a deficiency proposed by the IRS during an examination of the client's return. Depending on the procedural posture of the case, a student representative will call or meet with agents from the Internal Revenue Service to discuss the tax issue, write an appeal from the 30-day letter, or prepare a petition to Tax Court in response to the 90-day proposed deficiency letter. The Clinic has prepared a number of cases for Tax Court; however, a large majority of cases settle prior to trial.

Post-Assessment Cases

In post-assessment situations, the Clinic is generally involved in dealing with taxpayers' collection issues. As with all cases, the Clinic first determines a taxpayer's options for dealing with the tax liability. To accomplish this, the Clinic prepares a Form 433-A financial statement of the taxpayer. Based upon the calculations from the financial statement, the taxpayer's options are more narrowly defined. With respect to the tax liability, the Clinic advises the taxpayer as to the suggested course of action. Based upon the taxpayer's response, the Clinic may negotiate with the IRS to have them accept an Installment Agreement, accept a Form 656 Offer in Compromise or, if appropriate, place the client into "currently uncollectible" status . The Clinic also handles taxpayer matters by filing Form 8857 seeking innocent spouse relief.