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

Assessable penalties typically are expressed as a flat dollar amount and are usually imposed on third parties, such as tax return preparers.

Underpayment is defined in § 6664 as the correct amount of tax, less the sum of the amount of tax reported by the taxpayer on the return, plus any amount previously assessed or collected, less the amount of rebates made.

If a taxpayer understates gross income by 25 percent, the IRS has a 6-year statute of limitations on assessment.

The penalty for failure to make payment of quarterly estimated income taxes is computed without any daily compounding and is not deductible.

A fraudulent failure-to-file tax return is subject to a 25 percent monthly penalty.

Generally, an overpayment can be refunded or credited to the person who was subject to the original tax.

Which of the following would lead to imposition of civil penalties?

If a taxpayer fails to file her return due to willful neglect, the minimum penalty is:

List some of the possible defenses that a taxpayer may use against a charge of criminal tax offense.

The standard for conviction in a criminal case is establishment of:

The burden of proof in a fraud case is on the:

Could a taxpayer make such a small amount of income that a tax return not be filed and still have an unlimited statute of limitations on assessment?