Exam 15: Administrative Procedures

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How long does a taxpayer have to file a petition with the U.S. Tax Court following the date of the Statutory Notice of Deficiency?

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C

The IRS provides advice concerning an issue that arises during an audit by issuing

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A

On July 25 of the following year, Joy files her current calendar- year tax return without having requested an extension. On October 8, she pays the amount due. The tax shown on her return is $25,000. Her current- year withholding tax is $20,000. Joy pays no estimated taxes and does not claim any tax credits on her current year return. Calculate the penalties that the IRS is likely to assess. Ignore the penalty for underpayment of estimated taxes. Assume she did not commit fraud.

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Failure to-pay penalty-
0.005×($25,000−$20,000)×6 months $1500.005 \times ( \$ 25,000 - \$ 20,000 ) \times 6 \text { months }\quad \quad \$ 150
Failure- to-file penalty -
0.05×($25,000−$20,000)×4 months $1,0000.05 \times ( \$ 25,000 - \$ 20,000 ) \times 4 \text { months } \quad \quad \$ 1,000
Minus: failure- to-pay penalty for 4 months \quad (100) \quad900‾\underline { 900 }
Total penalties \quad$1,050\$ \mathbf { 1 , 0 5 0 }

Linda's individual tax return for the current year is subject to an IRS audit. The IRS assesses a $10,000 deficiency, $4,000 of which is due to Linda's negligence. What is Linda's negligence penalty?

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Lucy files her current- year individual income tax return on August 5 of the following year, without having requested an extension. Her total tax is $10,000. Lucy pays $7,500 in a timely manner and the $2,500 balance when she files the return. Lucy did not engage in fraud and has no reasonable cause for late filing and late payment. Compute Lucy's penalties.

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What is the requirement for a substantial understatement of tax for individuals?

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Gerald requests an extension for filing his last year's individual income tax return. His tax liability is $10,000, of which $8,000 was withheld, leaving a balance due of $2,000 when he files on August 1 of the current year. His penalty for failure to pay the tax on time is

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Explain accountant- client privilege. What are the similarities and differences between it and attorney- client privilege?

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Identify which of the following statements is true.

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Identify which of the following statements is false.

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Pablo, a bachelor, owes $80,000 of additional taxes, all due to fraud. What is the amount of the civil fraud penalty? What criminal fraud penalty might be imposed under Sec. 7201?

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Jeff's tax liability for last year was $30,000. Jeff projects that his tax for this year will be only $25,000. Jeff is self- employed and, thus, will have no withholding. His AGI for last year did not exceed $150,000. How much estimated tax, at a minimum, should Jeff pay for this year to avoid the penalty for underpayment of estimated taxes? How would your answer change if his income exceeded last year's due to a large capital gain at the end of the year?

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You are preparing the tax return for Agre Corporation, which has sales of $50 million. Agre made a $2 million expenditure for which the appropriate tax treatment, deductible or capitalizable, is a gray area. The corporation's Chief Financial Officer wants you to deduct the expenditure. What tax compliance issues should you consider in deciding whether to deduct the expenditure?

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Which, if any, of the following could result in penalties against an income tax return preparer? I. Knowing or reckless disclosure or use of tax information obtained in preparing a return. II) A willful attempt to understate any client's tax liability on a return or claim for a refund.

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One of your corporate clients has recently filed for bankruptcy. In the course of the proceedings, you (a) prepare a plan of reorganization that alters the rights of preferred stockholders, (b) notify the company's creditors of an impending bulk transfer of the company's assets, (c) review IRS secured claims against these assets, (d) restructure the company's debt by reducing its principal amount and extending its maturity, and (e) advise the bankruptcy court as to how this restructuring will impact the company's NOLs. Which of these activities, if any, constitutes the unauthorized practice of law?

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Identify which of the following statements is true.

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Identify which of the following statements is false.

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Identify which of the following statements is false.

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Pete has reported a tax liability of $3,500 on his 2016 tax return. His 2017 withholding was $3,800. He did not file his 2017 return until June 12, 2018. What penalties does Pete owe?

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Identify which of the following statements is true.

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