JANET R. SPRAGENS FEDERAL TAX CLINIC
Represent Taxpayers in Cases before the Internal Revenue Service and the U.S. Tax Court

The Janet R. Spragens Federal Tax Clinic is a one semester (six credit hours) clinic that teaches student attorneys the skills involved in representing clients who have commercial/business controversies. The clinic provides legal assistance to unrepresented, low income individuals who are being audited by the Internal Revenue Service.

It often comes as a surprise to students to learn that low income individuals have tax problems at all, or that low income taxpayer returns are audited to any significant extent. The reality is that anyone who files a tax return is subject to audit and that thousands of low income returns are audited each year. Tax clinic clients include cab drivers, travel agents, construction workers, retirees, flight attendants, nurses, high school teachers, car salesmen, waiters, immigrants, household workers, and many, many taxpayers with marginal businesses and terrible records. One of the clinic’s clients was a Nigerian immigrant whose sister-in-law had “borrowed” his social security number and used it on a bank account, which led to an audit on unreported income. Another was a male exotic dancer attempting to deduct some of his costumes. Another was a recently divorced woman seeking innocent spouse relief with respect to liability on joint returns filed during the marriage. Still another was a prisoner in a Virginia State Penitentiary who needed to produce documentation to support various return positions claimed.

Most clients are in the $10,000-$30,000 income range. Many are single parents with young children. A large number are minorities or ESL (English as a second language) taxpayers. They often lack higher education and literacy skills, and the dollar amounts to them are usually overwhelming and frighteningly large. Imagine a single working mother with two children earning $12,000 per year who receives a notice from the IRS that she erroneously claimed the earned income tax credit and now owes $2,000 in tax. Moreover, this is a unique clinic; the number of clinics nationwide helping people with tax problems is very small.

The Janet R. Spragens Federal Tax Clinic is a litigation clinic. The clinic does not fill out current tax returns for taxpayers, do bookkeeping or provide accounting services; rather, it offers legal representation for clients before the IRS in appeals conferences; and, if the cases do not settle, in U.S. Tax Court.

Janet R. Spragens Federal Tax Clinic student attorneys meet regularly on an individual basis with the faculty supervisors to discuss cases and strategy, and they also meet weekly as a group in a three hour seminar. The seminar encompasses a group review of the cases as well as discussions of other substantive, procedural and ethical issues related to tax representation. The Janet R. Spragens Federal Tax Clinic provides skills training in client interviewing and counseling, negotiating settlements, drafting memoranda and legal documents, keeping files, and other representational skills.