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

Which judicial doctrine means that a court will rule consistently with its previous rulings and the rulings of higher courts with appellate jurisdiction?

Dan received a letter from the IRS that gave him the choice of (1) requesting a conference with an Appeals Officer or (2) agreeing to a proposed tax adjustment.Dan received the:

Lakeisha,a 1^st year staff accountant,was researching a tax issue and found what appears to be the answer to her question in her introductory tax textbook that she bought three years ago.She is thrilled because she thought it would take much longer to find her answer.What type of authority is the textbook? What are other examples of this type of authorities? Can Lakeisha base her research conclusion on the textbook or similar authorities? Any suggestions for Lakeisha?

Henry filed his 2013 tax return on May 15^th,2014.The statute of limitations for IRS assessment on Henry's 2013 tax return should end:

An extension to file a tax return does not extend the due date for tax payments.

Proposed and Temporary Regulations have the same authoritative weight.

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:

Raul was researching an issue and found two Tax Court decisions issued within 6 months of each other,one for a taxpayer residing in California and the other for a taxpayer residing in New York whose rulings were inconsistent.Raul knows that the federal tax law does not differ by state and the issue was exactly the same in both cases.Raul is confused because he thought that a basic judicial doctrine was that a court is supposed to rule consistently.Name and describe this judicial doctrine that requires judicial consistency and discuss why the Tax Court may have intentionally ruled inconsistently in this example.

The "30-day" letter gives the taxpayer the opportunity to request an appeals conference or agree to the proposed IRS adjustment.

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

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

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

In researching a question of fact,the researcher will focus her efforts on identifying authorities with fact patterns similar to her client's facts.

Which of the following is not a source of a tax practitioner's professional responsibilities?

As required by the Constitution,all tax bills are supposed to originate in the House of Representatives.

Which types of penalties are only imposed after normal due process including a trial?

Which of the following is not considered a secondary authority?

Lavonda discovered that the U.S.Circuit Court of Appeals for the Federal Circuit 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:

The Internal Revenue Code and tax treaties are examples of statutory authorities.

Kodak is a beginning tax researcher.He knows that the 1^st step of the research process is to get an understanding of the facts surrounding the transaction being researched.Describe the two basic types of facts,the sources of facts for a research project,and any advice that may help Kodak.