Question 1

A client wants to take a tax return position with less than a 10% probability of being upheld in court.The CPA should

Accepted Answer

A)  take the client's desired position, but not sign the tax return. 
B)  inform the client that the position does not have a realistic possibility of success. 
C)  ask the client to sign a waiver of his right to sue the CPA in the event the IRS disallows the position. 
D)  take the client's desired position and sign the return as usual. 
A)  take the client's desired position, but not sign the tax return. 
B)  inform the client that the position does not have a realistic possibility of success. 
C)  ask the client to sign a waiver of his right to sue the CPA in the event the IRS disallows the position. 
D)  take the client's desired position and sign the return as usual.

Question 2

According to the Statements on Standards for Tax Services,CPAs must verify all tax return information submitted by reviewing client documentation.

Accepted Answer

A) True 
 B)False

Question 3

Which of the following citations is the primary citation for a U.S.District Court case?

Accepted Answer

A)  43 AFTR 2d 79-1023 
B)  79-1 USTC &9323 
C)  55 F.2d 930 
D)  40 F.Supp. 453 
A)  43 AFTR 2d 79-1023 
B)  79-1 USTC &9323 
C)  55 F.2d 930 
D)  40 F.Supp. 453

Question 4

Regulations are

Accepted Answer

A)  equal in authority to legislation. 
B)  equal in authority to legislation if statutory. 
C)  presumed to be valid and to have almost the same weight as the IRC. 
D)  equal in authority to legislation if interpretative. 
A)  equal in authority to legislation. 
B)  equal in authority to legislation if statutory. 
C)  presumed to be valid and to have almost the same weight as the IRC. 
D)  equal in authority to legislation if interpretative.

Question 5

Indicate which courts decided the case cited below.Also indicate on which pages and in which publications the authority is reported.
U.S.v.Maclin P.Davis,397 U.S.301,25 AFTR 2d 70-827,70-1 USTC & 9289 (1970).

Accepted Answer

This case appears in Vol.397,page 301,of

Question 6

Taxpayers must pay the disputed tax prior to filing a case with the Tax Court.

Accepted Answer

A) True 
 B)False

Question 7

A citator is used to find

Accepted Answer

A)  the judicial history of a case. 
B)  the cases that have cited a case subsequent to the issuance of the opinion. 
C)  whether a case has been overturned. 
D)  all of the above. 
A)  the judicial history of a case. 
B)  the cases that have cited a case subsequent to the issuance of the opinion. 
C)  whether a case has been overturned. 
D)  all of the above.

Question 8

In 1998,Congress passed legislation concerning shifting the burden of proof to the IRS.The taxpayer must introduce "credible evidence" to shift the burden of proof to the IRS.What constitutes "credible evidence?"

Accepted Answer

The term is not defined in the IRC.Becau

Question 9

Small case procedures of the U.S.Tax Court requires that the amount in dispute not exceed

Accepted Answer

A)  $5,000. 
B)  $10,000. 
C)  $50,000. 
D)  $100,000. 
A)  $5,000. 
B)  $10,000. 
C)  $50,000. 
D)  $100,000.

Question 10

What are the purposes of citations in tax research?

Accepted Answer

Citations serve two purposes.F

Question 11

If the U.S.District Court for Rhode Island,the Tax Court,and the Eleventh Circuit have all ruled on a particular issue,then what precedents have been set for which courts in the future?

Accepted Answer

Any U.S.District court within the Eleven

Question 12

The Tax Court decides an expenditure is deductible in the year the issue was first litigated.The government appealed and won a reversal in the Ninth Circuit Court of Appeals.It is the only appellate decision regarding the issue.If and when the Tax Court encounters this issue again,how will it hold?

Accepted Answer

The Tax Court will hold that t

Question 13

Discuss the purposes and scope of temporary regulations.

Accepted Answer

Temporary regulations are issued by the

Question 14

A Technical Advice Memorandum is usually

Accepted Answer

A)  an internal IRS document describing alternative legislative proposals. 
B)  part of a Tax Court decision. 
C)  requested by the taxpayer before entering into a taxable transaction. 
D)  issued by the national office in response to an audit request. 
A)  an internal IRS document describing alternative legislative proposals. 
B)  part of a Tax Court decision. 
C)  requested by the taxpayer before entering into a taxable transaction. 
D)  issued by the national office in response to an audit request.

Question 15

When the Tax Court follows the opinion of the circuit court of appeals to which the case is appealable,the court is following the

Accepted Answer

A)  Golsen rule. 
B)  Acquiescence rule. 
C)  Forum shopping rule. 
D)  Conformity rule. 
A)  Golsen rule. 
B)  Acquiescence rule. 
C)  Forum shopping rule. 
D)  Conformity rule.

Question 16

The primary citation for a federal circuit court of appeals case would be

Accepted Answer

A)  40 AFTR 2d 78-1234. 
B)  44 F.Supp. 403. 
C)  3 F.3d 134. 
D)  79-2 USTC & 9693. 
A)  40 AFTR 2d 78-1234. 
B)  44 F.Supp. 403. 
C)  3 F.3d 134. 
D)  79-2 USTC & 9693.

Question 17

You have the following citation: Joel Munro,92 T.C.71 (1989).Which of the following statements is true?

Accepted Answer

A)  The taxpayer, Joel Munro, won the case because there is no reference to the IRS. 
B)  The case appears on page 71 in Volume 92 of the official Tax Court of the United States Reports and the case was decided in 1989. 
C)  This citation refers to a taxpayer conference between the IRS and the taxpayer. 
D)  The case was tried in 1989 and was appealed in 1992. 
A)  The taxpayer, Joel Munro, won the case because there is no reference to the IRS. 
B)  The case appears on page 71 in Volume 92 of the official Tax Court of the United States Reports and the case was decided in 1989. 
C)  This citation refers to a taxpayer conference between the IRS and the taxpayer. 
D)  The case was tried in 1989 and was appealed in 1992.

Question 18

The citation "Reg.Sec.1.199-2" refers to

Accepted Answer

A)  the first regulation issued in 1999. 
B)  the second regulation issued in 1999. 
C)  a regulation that interprets Code Section 199. 
D)  a regulation that can be found on page 199. 
A)  the first regulation issued in 1999. 
B)  the second regulation issued in 1999. 
C)  a regulation that interprets Code Section 199. 
D)  a regulation that can be found on page 199.

Question 19

Identify which of the following statements is false.

Accepted Answer

A)  Regular and memorandum decisions of the Tax Court are published by the government in the Tax Court of the United States Reports. 
B)  The citation Cristofani, 97 T.C. 74 (1991) indicates that the decision is a regular decision of the Tax Court. 
C)  The citation Estate of Newhouse, 94 T.C. 193 (1990), nonacq. 1991-1 C.B. 1 indicates that the IRS did not formally disagree with this 1990 Tax Court decision until 1991. 
D)  The Board of Tax Appeals preceded the Tax Court. 
A)  Regular and memorandum decisions of the Tax Court are published by the government in the Tax Court of the United States Reports. 
B)  The citation Cristofani, 97 T.C. 74 (1991) indicates that the decision is a regular decision of the Tax Court. 
C)  The citation Estate of Newhouse, 94 T.C. 193 (1990), nonacq. 1991-1 C.B. 1 indicates that the IRS did not formally disagree with this 1990 Tax Court decision until 1991. 
D)  The Board of Tax Appeals preceded the Tax Court.

Question 20

Which regulation deals with Code Section 165?

Accepted Answer

A)  Reg. Sec. 1.165-5 
B)  Reg. Sec. 165.183-5 
C)  Reg. Sec. 1.5-165 
D)  Reg. Sec. 165-5 
A)  Reg. Sec. 1.165-5 
B)  Reg. Sec. 165.183-5 
C)  Reg. Sec. 1.5-165 
D)  Reg. Sec. 165-5

A client wants to take a tax return position with less than a 10% probability of being upheld in court.The CPA should

According to the Statements on Standards for Tax Services,CPAs must verify all tax return information submitted by reviewing client documentation.

Which of the following citations is the primary citation for a U.S.District Court case?

Regulations are

Indicate which courts decided the case cited below.Also indicate on which pages and in which publications the authority is reported. U.S.v.Maclin P.Davis,397 U.S.301,25 AFTR 2d 70-827,70-1 USTC & 9289 (1970).

Taxpayers must pay the disputed tax prior to filing a case with the Tax Court.

A citator is used to find

In 1998,Congress passed legislation concerning shifting the burden of proof to the IRS.The taxpayer must introduce "credible evidence" to shift the burden of proof to the IRS.What constitutes "credible evidence?"

Small case procedures of the U.S.Tax Court requires that the amount in dispute not exceed

What are the purposes of citations in tax research?

If the U.S.District Court for Rhode Island,the Tax Court,and the Eleventh Circuit have all ruled on a particular issue,then what precedents have been set for which courts in the future?

The Tax Court decides an expenditure is deductible in the year the issue was first litigated.The government appealed and won a reversal in the Ninth Circuit Court of Appeals.It is the only appellate decision regarding the issue.If and when the Tax Court encounters this issue again,how will it hold?

Discuss the purposes and scope of temporary regulations.

A Technical Advice Memorandum is usually

When the Tax Court follows the opinion of the circuit court of appeals to which the case is appealable,the court is following the

The primary citation for a federal circuit court of appeals case would be

You have the following citation: Joel Munro,92 T.C.71 (1989).Which of the following statements is true?

The citation "Reg.Sec.1.199-2" refers to

Identify which of the following statements is false.

Which regulation deals with Code Section 165?

Corporate Formations and Capital Structure

The Corporate Income Tax

Corporate Nonliquidating Distributions

Other Corporate Tax Levies

Corporate Liquidating Distributions

Corporate Acquisitions and Reorganizations

Consolidated Tax Returns

Partnership Formation and Operation

Special Partnership Issues

US Corporations

The Gift Tax

The Estate Tax

Income Taxation of Trusts and Estates

Administrative Procedures

US Taxation of Foreign-Related Transactions

Filters

Exam 1: Tax Research

A client wants to take a tax return position with less than a 10% probability of being upheld in court.The CPA should

According to the Statements on Standards for Tax Services,CPAs must verify all tax return information submitted by reviewing client documentation.

Which of the following citations is the primary citation for a U.S.District Court case?

Regulations are

Indicate which courts decided the case cited below.Also indicate on which pages and in which publications the authority is reported. U.S.v.Maclin P.Davis,397 U.S.301,25 AFTR 2d 70-827,70-1 USTC & 9289 (1970).

Taxpayers must pay the disputed tax prior to filing a case with the Tax Court.

A citator is used to find

In 1998,Congress passed legislation concerning shifting the burden of proof to the IRS.The taxpayer must introduce "credible evidence" to shift the burden of proof to the IRS.What constitutes "credible evidence?"

Small case procedures of the U.S.Tax Court requires that the amount in dispute not exceed

What are the purposes of citations in tax research?

If the U.S.District Court for Rhode Island,the Tax Court,and the Eleventh Circuit have all ruled on a particular issue,then what precedents have been set for which courts in the future?

The Tax Court decides an expenditure is deductible in the year the issue was first litigated.The government appealed and won a reversal in the Ninth Circuit Court of Appeals.It is the only appellate decision regarding the issue.If and when the Tax Court encounters this issue again,how will it hold?

Discuss the purposes and scope of temporary regulations.

A Technical Advice Memorandum is usually

When the Tax Court follows the opinion of the circuit court of appeals to which the case is appealable,the court is following the

The primary citation for a federal circuit court of appeals case would be

You have the following citation: Joel Munro,92 T.C.71 (1989).Which of the following statements is true?

The citation "Reg.Sec.1.199-2" refers to

Identify which of the following statements is false.

Which regulation deals with Code Section 165?

Corporate Formations and Capital Structure

The Corporate Income Tax

Corporate Nonliquidating Distributions

Other Corporate Tax Levies

Corporate Liquidating Distributions

Corporate Acquisitions and Reorganizations

Consolidated Tax Returns

Partnership Formation and Operation

Special Partnership Issues

US Corporations

The Gift Tax

The Estate Tax

Income Taxation of Trusts and Estates

Administrative Procedures

US Taxation of Foreign-Related Transactions

Filters