Exam 26: Tax Practice and Ethics

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With respect to the Small Cases Division of the Tax Court,

(Multiple Choice)
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Jaime's negligence penalty will be waived, under the reasonable cause exception. He told the court, "My taxes were wrong because I couldn't understand the tax law."

(True/False)
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The ________________ , a presidential appointee, is the "IRS's attorney."

(Short Answer)
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Michelle, a calendar year taxpayer subject to a 24% marginal Federal income tax rate, claimed a Form 1040 charitable contribution deduction of $275,000 for a sculpture that the IRS later valued at $200,000. The applicable overvaluation penalty is:

(Multiple Choice)
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Which statement does not correctly describe the IRS letter ruling process?

(Multiple Choice)
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During any month in which both the failure-to-file and failure-to-pay penalties apply, both penalties must be paid in full.

(True/False)
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As part of a tax return engagement for XYZ Partnership, Enrolled Agent Wang can draft an amendment to the XYZ partnership agreement.

(True/False)
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The "IRS's attorney" is known as the Chief Counsel.

(True/False)
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Attorneys are allowed an "attorney-client privilege" of confidentiality with clients. Does a CPA tax preparer enjoy the same privilege? On which types of tax and financial work?

(Essay)
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Cheng filed an amended return this year, claiming a refund relative to her tax computation on a prior-year's return. When the IRS approves the amended return and issues the refund, it also pays Cheng interest with respect to the overpayment.

(True/False)
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This official does not report directly to the IRS Commissioner.

(Multiple Choice)
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Match each of the following tax penalties with the type of tax penalty as specified by the Code. A letter can be used more than once. The correct solution may include more than one letter. a. Taxpayer penalty b. Tax preparer penalty c. Appraiser's penalty -Substantial understatement of a tax.

(Short Answer)
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During an audit, the IRS might require that the taxpayer produce the ________________ that underlie the tax return data.

(Short Answer)
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Malik, Inc., a calendar year C corporation subject to a 21% marginal income tax rate, claimed a Form 1120 charitable contribution deduction of $30,000 for a sculpture that the IRS later valued at $10,000. The applicable overvaluation penalty is:

(Multiple Choice)
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Juanita, who is subject to a 40% marginal Federal gift tax rate, made a gift of a sculpture to Bianca, valuing the property at $150,000. The IRS later valued the gift at $300,000. The applicable undervaluation penalty is:

(Multiple Choice)
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The IRS targets high-income individuals for an audit rate that is much higher than that of the general populace.

(True/False)
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In preparing a tax return, a CPA should verify "to the penny" every item of information submitted by a client about its deduction for repairs and maintenance.

(True/False)
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IRS computers use document matching programs for both individuals and business taxpayers to keep the audit rate low.

(True/False)
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In connection with the taxpayer penalty for substantial understatement of tax liability, what defenses (if any) are available?

(Essay)
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Evaluate this statement: a taxpayer is liable not only for tax penalties as described in the tax Code and Regulations. Sanctions elsewhere in Federal law, such as in the criminal code, also apply in a tax dispute.

(Essay)
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