This fall, Kostelanetz & Fink partners Megan Brackney and Caroline Ciraolo will be teaching undergraduate and graduate level courses again at New York University School of Law (Brackney), Georgetown University Law Center (Ciraolo), and the University of Baltimore School of Law and Graduate Tax Program (Ciraolo).
The courses reflect the deep level of experience both Ms. Brackney and Ms. Ciraolo have in the fields of civil and criminal tax procedure, investigations and defense.
In this course, Ms. Brackney will survey civil tax procedure from a practitioner’s perspective. The course will discuss audits, assessments, collection, and judicial review, and the many practical and ethical issues that arise when representing taxpayers in controversies, such as the IRS’s summons authority, privileges, penalties, and interest.
Ms. Ciraolo will present a course on criminal tax law and procedure. The course reviews the federal criminal tax offenses and the elements the government must prove, including the key concept of willfulness. Students will learn the various stages of a criminal tax case including potential sources of investigations, key government personnel involved, the respective roles of the Internal Revenue Service, the Justice Department, the federal courts, and related agencies, plea negotiations, trial strategies, and best practices. Students will review current IRS and Department of Justice enforcement priorities and high-profile criminal tax cases “ripped from the headlines.”
University of Baltimore School of Law: Investigation, Prosecution and Defense of Tax Crimes
Ms. Ciraolo’s course on the life cycle of a criminal tax case reviews the various stages of a criminal tax case, starting with civil tax matters referred to IRS Criminal Investigation, cases that originate outside the IRS, and grand jury investigations that are expanded to include tax charges. The course also will explore the potential charges and defenses, methods of investigation, the authorization process, plea negotiations, trial strategies, sentencing, and collateral consequences. Through coursework and reviews of pending real-world criminal proceedings, students will learn how to spot potential criminal tax cases and how to best represent their clients in private practice or within the government.