The work at the clinic is hands-on and heartwarming and I am gaining useful legal experience while doing it.
The Federal Tax Clinic helps low-income individuals throughout Western Washington resolve disputes with the Internal Revenue Service. The clinic offers this assistance as a public service and as a means of training law students in tax practice. The Tax Clinic has added a pro bono panel of volunteer attorneys to assist the growing number of low-income taxpayers who have disputes with the IRS. There are currently 25 volunteer attorneys on the panel. In 2023, the clinic closed cases that decreased tax liabilities, penalties and interest by $4,159,508 for taxpayers.
Each student and volunteer attorney is the first chair attorney for their case. Students do not generally work in teams but are responsible for their own cases.
The Clinic represents clients at all levels of the IRS, from examination to appeals and collections and in the federal courts. Most cases are resolved administratively.
The Clinic had three reported cases in the United States Tax Court in recent years. In Roberts v. Commissioner, 141 T.C. No.19 (2013), the Tax Court found that the taxpayer’s ex-wife withdrew funds from his IRA without his consent. The Court held that even though the taxpayer was the owner of the IRA, because he did not request, receive or benefit from the IRA distributions, he should not be taxed on the withdrawal. In Bogart v. Commissioner, T.C. Memo. 2014-46, the Court held that the IRS abused its discretion in failing to address the equitable grounds raised by the taxpayers in their collection due process hearing. In Park v. Commissioner, No. 15418-16S (T.C. Sept. 24, 2018), the Court held that petitioner presented credible evidence that a $12,789 deposit was reimbursement from Bank of America (BOA) for a mistake that BOA had made on his accounts. This return of $12,789 of petitioner’s mortgage payments was not a taxable event, and the amount was therefore not includible in income.
Note: The clinic does not generally provide tax return preparation.
By separately applying to enroll in LAW T 506 Tax Practice and Skills, many Tax Clinic students also spend one week in February preparing tax returns for villagers in rural Alaska. This tax preparation program is sponsored by the Alaska Business Development Corporation and the Graduate Program in Taxation at the UW School of Law. In 2024, 15 communities were served by 20 UW Law students participating in the Rural Alaskan Tax Program.
Scott Schumacher, faculty director, is the co-author of the book Tax Crimes, published by LexisNexis. See Schumacher’s other published works.
In the ABA’s 9th edition of Effectively Representing Your Client Before the IRS, Ramón E. Ortiz-Vélez, managing director, is co-author of Chapter 33: “Understanding the Intersection of Taxation and Immigration.
One student’s experience volunteering with the University of Washington School of Law Federal Tax Clinic. (Source: WA Bar News; Illustration © Getty/Irina_Strelnikova.)
Recent victories by Federal Tax Clinic students include protecting an innocent spouse from $1.2M in liability.
There are many reasons why Erick Quezada chose to study taxation—but helping people tops the list.
Students worked a total of 271 cases, saving taxpayers over $800,000 and procuring refunds of more than $125,000.
The story of how Jin Park and John Clynch met spans two decades and ends — as it so often does for students in the Federal Tax Clinic — with justice being served.