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

Josephine is considering taking a 6 month rotation in Paris for her job. Which type of authority may be especially helpful in determining the tax consequences of Josephine's job in Paris?

Of the two basic types of tax services, beginning tax researchers often prefer topical tax services.

Kim has decided to go to litigate a tax issue with the IRS. Describe the trial level courts that Kim may use to litigate the case.

Henry filed his 2014 tax return on May 15th, 2015. The statute of limitations for IRS assessment on Henry's 2014 tax return should end:

In general, a CPA will satisfy his professional responsibilities under the Statement on Standards for Tax Services when recommending a tax return position if he complies with the standards imposed by the applicable tax authority.

Mary Ann is working on a pretty big research project. Her manager has alerted her to the possibility that some of her research questions are likely to be questions of fact, whereas others are likely to be questions of law. Explain the difference between the two types of questions and how this would influence her research.

This year April 15th falls on a Saturday. Individual tax returns will be due on:

Greg earned $20,500 this year and had $1,500 of federal income taxes withheld from his salary. Assuming that Greg will have a total tax liability of $1,000 (and thus will receive a $500) refund, he:

Which of the following is not a factor that determines whether a taxpayer is required to file a tax return?

If Lindley requests an extension to file her tax return, the latest she could pay her tax due without penalty is:

Tina has a very complex tax return and it looks like she will not be able to file her tax return by its due date. When is her tax return due? What are Tina's options for paying her tax due and filing her tax return this year? What are the consequences if Tina does not file or pay her tax timely? Be specific. Tina's tax return is due April 15th. Tina may request an automatic 6 month extension to file her tax return (i.e., until October 15th). Extensions allow the taxpayer to delay filing a tax return but

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.

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

Houston has found conflicting authorities that address a research question for one of his clients. The majority of the authorities provide a favorable answer for his client. Nonetheless, there are several authorities that provide an unfavorable answer. Houston estimates that if the client takes the more favorable position on its tax return that there is approximately a 60 percent chance that the position will be sustained upon audit or judicial proceeding. If the client takes this position on its tax return, will Houston be subject to penalty? Will the client potentially be subject to penalty?

Closed facts are especially conducive to tax planning.

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?

If the President vetoes tax legislation, Congress:

According to Statement on Standards for Tax Services No. 1, a tax practitioner can recommend a tax return position:

For fraudulent tax returns, the statute of limitations for IRS assessment is ten years.

The "90-day" letter gives the taxpayer the opportunity to pay the proposed tax adjustment or file a petition in the U.S. District Court to hear the case.