T. Keith Fogg is a Professor of Law and Director of the Federal Tax Clinic at
Villanova University School of Law. Professor Fogg received his B.A. from the College of
William and Mary, his J.D. from the University of Richmond T.C. Williams School of Law,
and his LL.M. from the College of William and Mary Marshall Wythe School of Law. He
worked for 30 years as a lawyer in the Office of Chief Counsel of the Internal Revenue
Service, where he served both in the national office and field offices. Prior to coming
to Villanova Law in 2007, he was Senior Counsel in the Richmond Office, where he handled
sensitive collection and bankruptcy matters. He also served as an advisor when Congress
passed the last major procedural tax reform legislation. He has also taught as an adjunct
professor at Georgetown, Richmond, and William and Mary, and was a visiting professor at
the University of Arizona School of Law. 

Tax History

Low-Income Taxpayer Issues

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Effectively Representing Your Client Before the IRS, 6th edition (2015)

"Written by some of the most experienced tax controversy lawyers in the United States, this...

 

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Obtaining Relief From Federal Tax Levies, Effectively Representing Your Client Before the IRS, 6th edition (2015)

A levy is an administrative means of collecting taxes by seizure or taking of the...

 

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Obtaining Relief From Federal Tax Lien (with Frank Agostino), Effectively Representing Your Client Before the IRS, 6th edition (2015)

The Supreme Court has said that Congress could not have chosen broader language than it...

 

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Utilizing Bankruptcy to Reduce Outstanding Tax Debts (with Kenneth C. Weil), Effectively Representing Your Client Before the IRS, 6th edition (2015)

In general, Congress set out to strike a balance in the bankruptcy code between the...

 

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Tax Issues Facing Clients of Legal Services, MIE Journal (2014)

This article seeks to highlight tax issues facing clients of legal services. It discusses several...

 

Collecting Trust Fund Taxes

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Transparency in Private Collection of Federal Taxes, Florida Tax Review (2011)

Most federal taxes are collected from taxpayers by business entities, held in a public trust...

 

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In Whom We Trust, Creighton Law Review (2010)

The Internal Revenue Service ("IRS") collects the majority of taxes through business entities that are...

 

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Leaving Money on the Table and Providing an Incentive Not to Pay -- The Story of a Flawed Collection Device, Hastings Business Law Journal (2009)

As of September 30, 2007, the IRS had $282-billion of unpaid assessments on its books....

 

General Tax Procedure Issues

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Tax Court Decisions "Shall Be Made As Quickly As Practicable" - A Discussion of Bench Opinions, Journal of Tax Practice and Procedure (2015)

Keith Fogg discusses the legal and practical bases of bench opinions, what causes the Tax...

 

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Does the Failure to Timely Issue Notice and Demand Impact the Underlying Assessment Rather Than the Just Liens or Levies?, Journal of Tax Practice & Procedure (2014)

This article analyzes the impact a failure to send notice and demand might have on...

 

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What Is a Return -- The Long Slow Fight in the Bankruptcy Courts, Journal of Tax Practice & Procedure (2013)

This article examines what constitutes a return within the context of a bankruptcy for purposes...

 

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Book Review: A Practitioner's Guide to Tax Evidence (2013)

This is a book review of Joni Larson's book: A Practitioner's Guide to Tax Evidence...

 

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Tax Court Collection Due Process Cases Take Too Long (with Carlton M. Smith), Tax Notes (2011)

This report documents through Tax Court records the time it takes to complete CDP cases...