Exam 2: Tax Compliance, the Irs, and Tax Authorities

Jeremy has a new client.He has identified a research question that relates to a transaction that the client completed several months ago.This type of research question will primarily involve:

Proposed and Temporary Regulations have the same authoritative weight.

Lavonda discovered that the 5ᵗʰ Circuit (where Lavonda resides)has recently issued a favorable opinion with respect to an issue that she is going to litigate with the IRS.Lavonda should choose which of the following trial courts to hear her case:

Which of the following is a false statement? A taxpayer filing a fraudulent tax return:

Which of the following has the highest authoritative weight?

Corporations are required to file a tax return only if their taxable income is greater than:

Which of the following has the lowest authoritative weight?

Caitlin is a tax manager for an accounting firm,and Duff is a first year staff accountant.Describe the differences in the manner in which Caitlin and Duff may identify research issues and in general how one may identify research questions.

Office examinations are the most common type of IRS audit.

A client has recently learned of a proposed tax bill that would increase the tax rates on investment gains by 5 percent.The President does not support this increase.Please describe for your client the process by which new tax legislation is created and how the President's disapproval may influence the enactment of the bill.

Rebecca is at a loss.A new tax law was recently passed,and she needs to get a better understanding of why the tax law was passed and the intent of the law from an official authority.Describe what authorities may be especially helpful to Rebecca and why she can't find many authorities that discuss the new law.

Roddy was researching an issue and found a favorable Tax Court decision that addresses his issue.He also determined that there was a nonacquiescence for the case.Who issued the nonacquiescence? What is it? What does it mean and how would it affect Roddy's reliance on the court case?

Which of the following audits is the least common,broadest in scope,and typically most complex?

Which of the following is not a common tool used in conducting tax research?

Henry filed his 2018 tax return on May 15ᵗʰ,2019.The statute of limitations for IRS assessment on Henry's 2018 tax return should end:

If the President vetoes tax legislation,Congress:

Secondary authorities are official sources of the tax law with a lesser "weight" than primary authorities.

Chris and Chuck were recently debating whether the Internal Revenue Code is "logical." Chris offers that she has briefly reviewed the Code and could hardly understand its organizational structure,if there is one.Please describe the basic organization of the code and how understanding its organization may be especially beneficial to the tax researcher.

For the following taxpayers,please recommend the most advantageous trial level court(s)to litigate a tax issue with the IRS. a.Joe is litigating a tax issue with the IRS that is considered a question of fact (i.e.,the answers depends on the facts of the case).There is not a lot of authority on point for this case but Joe has a very appealing story to justify his position that is likely to be viewed sympathetically by his peers. b.The Circuit Court of Appeals for the Federal Circuit recently issued an opinion that is very favorable to the issue that Jesse plans to litigate with the IRS. c.The Circuit Court of Appeals for the Federal Circuit recently issued an opinion that is not favorable to the issue that Hank plans to litigate with the IRS. d.The 7ᵗʰ Circuit (where Elizabeth resides)recently issued an opinion that is very favorable to the issue that Elizabeth plans to litigate with the IRS.

Basu received a letter from the IRS that gave him the choice of (1)paying a proposed deficiency or (2)filing a petition with the U.S.Tax Court.Basu received the: