Tackling IRS Disputes for Low-Income Washingtonians

One student’s experience volunteering with the University of Washington School of Law Federal Tax Clinic

BY SARAH B. MURPHY

The University of Washington School of Law Federal Tax Clinic helps low-income individuals throughout Western Washington resolve disputes with the Internal Revenue Service. As a law student, I helped clients navigate their tax disputes and advocate on their behalf with the IRS. Students take on cases that focus on tax controversies through litigation and tax administrative appeals with the federal government. 

GETTING INVOLVED

After nearly five years in New York City working in media and publishing, I returned to my home state of Washington to attend law school at Seattle University, graduating in May 2024. I entered law school with an interest in estate planning. I recall being at 1L orientation and learning about the different clinics students could participate in, including the University of Washington School of Law’s Federal Tax Clinic. Immediately, I began planning my next three years and how it would include participating in that clinic. At the start of my 3L year, I was accepted into UW’s tax clinic as one of two Seattle University School of Law students who participate every semester. I quickly took to the work and enjoyed problem solving for clients. Tax is an intimidating field, especially for someone like me who majored in English and did everything they could to avoid math. I quickly realized that being (highly) skilled in math is not required, but being savvy, determined, and seeing cases to completion is greatly valued. At the end of my fall semester at the clinic I had a conversation with managing director Ramón Ortiz-Vélez about coming back to the clinic in the spring as an advanced clinic student, which I quickly agreed to. Today, I am a law clerk at McGavick Graves, P.S., in Tacoma working in estate planning. I have been accepted to the University of Washington School of Law LL.M. program in tax, to start after the February 2025 bar exam. I will continue working with the tax clinic during my LL.M. studies, and after graduation I plan to contribute as a volunteer attorney. 

WORKING IN THE TAX CLINIC

As a law student volunteer, I mainly worked on cases that were headed to the United States Tax Court. I successfully resolved a case for a couple in Hawaii who were denied their tax refund, including their Child Tax Credit (including the COVID-19-era increase) and stimulus payments. The IRS denied their child tax credit and froze their refund because they claimed that the wages earned were fraudulent. To prove the wages were accurate, and that they had a son in the calendar year, I collected copies of pay stubs, birth certificates, Social Security cards, statements from accountants and employers on official letterhead, and other evidence to attach to the appeal. After unsuccessful negotiation with the IRS Independent Office of Appeals, the tax clinic filed a petition in Tax Court. Once the case was assigned to a trial judge, I was able to contact the IRS attorney directly and work together to submit a decision document to the Tax Court. Ultimately, the couple received their $7,000 refund. While working on this case, I was closely supervised by managing director Ortiz-Vélez, who provided guidance on each step of the appeals process, and staff attorney John Clynch, who connected me directly with local IRS attorneys and taught me the importance of speaking to opposing counsel over the phone to resolve a case. 

In another case, the statute of limitations on collections (10 years) had expired, and it was exciting to make the call informing the taxpayer that they no longer owed the IRS $180,000. 

In a third case, a Tribal fisherman was taxed in direct violation of the Treaty of Point Elliot. The client not only received his withheld funds of $700, but the decision by the IRS to abide by the Treaty was monumental and will support similar cases and individuals in the future.

The tax clinic, which was established in 2000 by current faculty director Scott Schumacher, is the only one of its kind in Western Washington and a vital part of the community. It receives referrals from the Taxpayer Advocate Service (an independent organization within the IRS), accounting firms, law firms, and through educational outreach. The clinic consistently has students and other volunteers who speak multiple languages and are able to assist taxpayers for whom English is not a first language. As part of the clinic curriculum, students do educational presentations on common tax issues—e.g., how to file taxes, what happens if you file late, how to get on “currently not collectible” status with the IRS—to communities including teens, refugees, incarcerated persons, and senior citizens. By offering this public service to the most vulnerable populations in Western Washington, students are not only reaching a broader population to get the word out about the clinic’s services but are also networking with attorneys and programs that do great work in the community. 

When students first start at the tax clinic, they are most likely to take over cases of other students who have graduated or left the clinic. Students write transfer memos that are kept in client files to help the next student volunteers get up to speed with the case and know where to pick up. Client files are kept organized with notes from previous meetings with clinic staff and directors, any client communications, and next steps. Although it can be intimidating to start working with clients immediately, students are mentored throughout the process by Ortiz-Vélez, Clynch, and Faculty Director Scott Schumacher.

The clinic works as a training ground for law students in tax practice, and students are frequently reminded to treat clinic office hours like work at a law firm. Almost any transaction an attorney will encounter can involve tax. Helping people during some of the worst times of their lives is rewarding, provides on-the-job learning opportunities, and teaches students the importance of being organized and following through. Working in such an environment increases students’ confidence that they will be able to do research and ask the right questions in their own practice. Many lasting relationships have been created among tax clinic alumni across Washington who are more than happy to do informational interviews with students. 

Volunteer attorneys, accountants, and enrolled agents are also extremely important to the clinic because they can provide assistance to clients under the supervision of the clinic directors based on the volunteers’ experience. I look forward to coming back to the clinic as a volunteer attorney. 

The clinic is always ready to train and mentor volunteers. If you are interested in volunteering, contact John Clynch at clyncher@uw.edu. 

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SIDEBAR

New Veterans Clinic

Ramón Ortiz-Vélez and John Clynch are now spearheading the opening of the University of Washington School of Law Veterans Clinic. The Veterans Clinic is designed to educate students in the practice of veterans law—particularly Title 38 U.S.C. (Veterans’ Benefits), the Veterans Appeals Improvement and Modernization Act of 2017, the VA Mission Act of 2018, PACT Act expanded benefits, and other relevant statutory authorities—by affording them hands-on training and first-chair experience in military discharge upgrades and appeals regarding benefit claims under the supervision of the clinic’s director and staff attorney. Students will advise and represent qualified veterans and family members in administrative and litigation procedures affecting their claims. Students will also engage in consultations and additional multidisciplinary legal work, identifying and undertaking representation on other issues as resources allow, to better assist and serve the clients. For more information about the Veterans Clinic, contact 206-685-4084 or UW-VC@uw.edu.