Exam 15: Administrative Procedures

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A letter ruling is a written determination that interprets and applies the tax laws to the taxpayer's specific set of facts.

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The IRS will issue a ruling

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The 90- day letter (Statutory Notice of Deficiency) gives the taxpayer 90 days to file a petition with the Tax Court or to pay the disputed tax.

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The "Statement on Practice in the Field of Federal Income Taxation" includes all of the following areas of mutual competence except

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A taxpayer will receive a 30- day letter

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Explain the four conditions that must be met in civil cases for the burden of proving any factual issue relevant to the determination of taxpayer liability to rest with the IRS.

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Identify which of the following statements is false.

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The IRS audited the tax returns of Dan Jackson, a gifted painter. It contended that, between 2003 and 2005, Jackson received $500,000 for his paintings, but reported only $75,000. Jackson attributed the shortfall to his receipt of cash at art fairs and street fairs. He allegedly concealed the cash payments in separate bank accounts unbeknownst to his CPA. What tax compliance issues regarding the alleged underreporting are pertinent to the CPA?

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What is the penalty for a tax return preparer who lacks substantial authority to take a return position?

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How does a taxpayer determine if "substantial authority" exists for a tax treatment the taxpayer desires to adopt?

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A six- year statute of limitation rule applies if the taxpayer

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A calendar- year individual taxpayer files last year's income tax return on October 17 of the current year. No extension was requested, and there is not a reasonable cause for the late filing. The return shows a balance due of $1,500 of tax. The late filing penalty is

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Kelly, a calendar- year taxpayer, files her 2008 individual return on March 30, 2013, and pays the amount due at the same time. Later, she discovers some deductions that she should have claimed on the return. By what date must she file a claim for refund?

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The "automatic" extension period for filing an individual return is seven months.

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What is the penalty for a tax return preparer who willfully attempts to understate taxes, or intentionally disregards the tax rules and regulations?

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Which of the following activities is protected by accountant- client privilege?

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The statute of limitations is unlimited for a tax return that is never filed.

(True/False)
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The taxes shown on Kate's tax returns for 2012 and 2013 were $6,000 and $9,000, respectively. Kate's withholding tax for 2009 was $7,000 and she paid no estimated taxes. Kate filed her 2013 return on April 3, 2014, but she did not have sufficient funds to pay the balance due. She pays the $2,000 balance due on June 19, 2014. Kate's AGI for 2013 did not exceed $150,000. Calculate the penalties Kate owes on her 2013 tax return.

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Richard recently won a popular television reality show and its one million dollar prize. However, he omitted the prize money from his tax return for the year. What penalties can the IRS assess?

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How does the IRS regulate the activities of compensated tax return preparers? In particular, list six acts that will cause a compensated tax return preparer to incur a penalty.

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