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For Internal Revenue Service

Internal Revenue Service

Government Agencies

Fall; Spring; Summer; 6 Credit


Factual Investigation; Legal Research & Analysis; Negotiation; Transactional Drafting; Writing for Litigation

Work Description


We counsel the I.R.S. on all aspects of determining and collecting federal taxes. We litigate for the U.S. in the Tax Court defending proposed assessments and in other Tax Court procedures. We refer collection and bankruptcy cases to the U.S. Attorney and Justice Department for suit and defense. We also counsel on tax and financial crimes.


With review, supervision, and some mentoring, students would be able to substantially participate in all activities outlined in item 2 with the exception of appearing before the courts as counsel. They would be able to "second chair" in some cases. They would conduct conferences with taxpayers, issue and respond to discovery, subpoena witnesses, and make similar trial preparations. They would be able to take a case from answer to second chair to preparing post trial briefs. Often such cases take more than one semester to complete, so the student would likely work on segments of several cases. The student would also research and write suit and defense letters as well as advisory memoranda on various tax, collection, bankruptcy, and/or criminal topics.


Courses in tax law, bankruptcy, Article 9 UCC, and Trial Practice would tend to distinguish a student as most suitable for work in our office, but these are not specifically required for an externship. The student should have a satisfactory history of filing and paying taxes and be able to pass an FBI background check. Spring externs are encouraged to accept an offer as soon as possible to allow for the completion of the background check prior to the start of the externship. Initial background forms and a transcript should be included with the application packet.

Must be first choice - must submit security clearance forms and transcript with application. All hours must be done on site. Basic tax law course must have been taken. 6 Credit may be preferred.

UNC School of Law | Van Hecke-Wettach Hall | 160 Ridge Road, CB #3380 | Chapel Hill, NC 27599-3380 | 919.962.5106 | Accessibility

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