Exam 2: The Tax Practice Environment

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What is the difference between a primary and a secondary source of tax authority?

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Primary sources of tax authority come from statutory, administrative, and judicial sources. Secondary sources consist of tax services (reference services), books, journals and newsletters; these are used to assist researchers in locating and interpreting the primary sources.

Acquiescence by the Internal Revenue Service's Commissioner means that the IRS will follow the decision in the future.

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Joaquin did not have any money to pay his $2,000 tax liability on April 15 so he did not file his tax return. He finally filed the return on July 25 and paid $1,000 of the tax due. He paid the remaining tax due on October 18. What is his total penalty?

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$415; (4 months x .05 x $2,000) + (3 months x .005 x $1,000) = $415.

The business purpose doctrine requires a transaction to have an economic purpose other than one based solely on tax avoidance.

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An individual may apply for an automatic extension of time to file a return of

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What is the unextended due date for a corporation with a March 31 year-end?

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Explain the difference between a closed fact and an open fact transaction.

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15 The Cumulative Bulletin contains reports of all the committees involved in tax writing as well as statements made on the floor of the House or Senate.

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The Internal Revenue Code is divided into

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A closed-fact situation means that

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William just did not like figuring out his taxes each year and he usually had so little income that he didn't owe taxes. He never filed an extension even though he seldom got around to filing before October or November. He finally filed his 2017 return in September of 2018 when he remembered he had sold some stock in early 2017 for a small profit. Unfortunately, he owed $125 in taxes because of the sale. What is William's failure to file penalty?

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The primary source of tax authority that provides explanations, definitions, and examples of tax laws is the

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Crispen Corporation can invest in a project that costs $400,000. The project is expected to have an after-tax return of $250,000 in each of years 1 and 2. Crispen normally uses a 10 percent discount rate to evaluate projects but feels it should use 12 percent to compensate for inflation. How much difference does the rate make in the after-tax net present value of the project?

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To which trial courts may a taxpayer contest a decision of the IRS?

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What is meant by the phrase "substance-over-form"?

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A six-year statute of limitations applies if the taxpayer

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The Internal Revenue Service has the burden of proof when it is asserting fraud with the intent to evade taxes on the part of the taxpayer.

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Merced Company has invested $200,000 in a project. It had before tax net income of $100,000 in year 1, $150,000 in year 2, and $125,000 in year 3. What is the net present value of this project's after-tax net cash flow if Merced's discount rate is 8 percent and its marginal tax rate is 21 percent in all years?

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Explain the step transaction doctrine.

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Which of the following types of returns does not have an unextended due date of the 15th day of the 4th month after the end of the tax year?

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