Exam 14: Tax Practice and Administration: Sanctions, Agreements, and Disclosures

A failure-to-pay penalty is imposed when the taxpayer fails to pay either a tax shown on his or her return or an assessed deficiency within 10 days of an IRS notice or demand.

"In case of both civil and criminal frauds, the burden of proof is on the IRS." Explain.

Assessable penalties are subject to review by the Tax Court.

A tax return preparer (TRP) is:

The maximum annual penalty that a TRP could be assessed is:

Penalties that are based on a percentage of the delinquent tax are referred to as:

What are the requirements to be satisfied for the issue of an injunction by the IRS against a TRP who is guilty of misconduct to prohibit him or her from engaging in such misconduct or from practicing as a return preparer?

The number of days the IRS is allowed in which it may refund an overpayment without incurring interest is:

The statute of limitations refers to a:

For § 6502, requests for equitable relief may be filed within:

When a taxpayer is subject to both underpayment and overpayment computations for the same time period, which of the following rates of interest applies to the net amount payable to or receivable from the government?

Give an example of what it means for failure to make deposits of taxes. Describe the penalties involved.

A taxpayer can avoid the failure-to-file penalty if an extension of the return's due date is granted by the IRS.

Noel, a calendar-year taxpayer, filed his 2016 income tax return on October 20, 2017, paying an amount due of $2,000. On April 1, 2017, he had obtained a six- month extension of time in which to file his return. However, he could not assert a reasonable cause for failing to file the return by October 15, 2017 (the extended due date), nor did he show any reasonable cause for failing to pay the tax that was due on April 15, 2017. Noel's failure to file was not fraudulent. The penalty for failure-to-pay tax is:

How do the courts define reasonable cause? List the examples of reasonable cause.

The civil fraud penalty is:

William, a taxpayer, timely mailed his tax return. However, it was returned for insufficient postage. IRS imposed a penalty. Can William claim waiver of penalty?

When the accuracy-related penalty applies, interest on the penalty accrues from the:

A tax return preparer may disclose information obtained from the taxpayer without being subject to civil and criminal penalty if such disclosure is:

Interest imposed by the IRS is compounded: