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Because the U.S. District Court hears a broader set of cases, decisions by the U.S. District Court may be considered to have more authoritative weight than those by the U.S. Court of Federal Claims.

A) True
B) False

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In a planning context,


A) closed facts are preferred to open facts.
B) new facts are preferred to old facts.
C) old facts are preferred to new facts.
D) open facts are preferred to closed facts.
E) None of the choices are correct.

F) A) and B)
G) A) and C)

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Princess, who resides in the 2nd Circuit, recently found a circuit court case that is favorable to her income tax research question. Which of the following circuits would she prefer to have issued the opinion?


A) 2nd Circuit.
B) Federal Circuit.
C) 1st Circuit.
D) 2nd Circuit or the Federal Circuit.
E) None of the choices are correct.

F) A) and D)
G) A) and C)

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Rowanda could not settle her tax dispute with the IRS at the appeals conference. If she wants to litigate the issue but does not have sufficient funds to pay the proposed tax deficiency, Rowanda should litigate in the:


A) U) S. District Court.
B) U) S. Circuit Court of Appeals.
C) U) S. Court of Federal Claims.
D) Tax Court.
E) None of the choices are correct.

F) A) and C)
G) B) and E)

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


A) criminal penalties.
B) civil penalties.
C) criminal and civil penalties.
D) Failure-to-file penalty.
E) None of the choices are correct.

F) None of the above
G) B) and E)

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A

If a taxpayer loses a case at the circuit court level, he is granted an automatic appeal hearing with the Supreme Court.

A) True
B) False

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Joel reported a high amount of charitable contributions as a deduction on his individual tax return relative to taxpayers with similar income levels. The information matching program is the IRS program most likely to identify Joel's tax return for audit.

A) True
B) False

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The IRS has recently completed its audit of Lorene's corporation. As a tax novice, she has very little understanding regarding the audit process and what happens next. Describe the post-audit process for Lorene and identify her options.

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After the examination, the IRS agent pro...

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Circular 230 was issued by:


A) AICPA.
B) State boards of accountancy.
C) American Bar Association.
D) IRS.
E) None of the choices are correct.

F) B) and E)
G) All of the above

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Which of the following is not a common method that the IRS uses to select returns for audit?


A) DIF system.
B) Tax Select system.
C) Information matching.
D) Document perfection.
E) None of the choices are correct.

F) A) and D)
G) All of the above

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


A) Filing status.
B) Taxpayer's gross income.
C) Taxpayer's employment.
D) Taxpayer's age.
E) None of the choices are correct.

F) None of the above
G) A) and E)

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C

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.

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The Internal Revenue Code is segregated ...

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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:


A) 30-day letter.
B) 90-day letter.
C) Appeals letter.
D) Tax adjustment letter.
E) None of the choices are correct.

F) C) and D)
G) C) and E)

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A taxpayer can avoid a substantial understatement of tax penalty:


A) if the position is frivolous and disclosed on the tax return.
B) if the position has a realistic possibility of being sustained by the IRS or courts.
C) if there is substantial authority to support the position.
D) if the position has a reasonable basis and is not disclosed on the tax return.
E) None of the choices are correct.

F) A) and B)
G) All of the above

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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.

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Two basic types of issues that researche...

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The "30-day" letter gives the taxpayer the opportunity to request an appeals conference or agree to a proposed IRS adjustment on the taxpayer's income tax return.

A) True
B) False

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An acquiescence indicates that the IRS lost a court case and that it has decided to follow the court's ruling in the future.

A) True
B) False

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True

Which of the following has the lowest authoritative weight?


A) Legislative regulation.
B) Private letter ruling.
C) Revenue ruling.
D) Interpretative regulation.
E) Revenue procedure.

F) A) and D)
G) A) and C)

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

A) True
B) False

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

A) True
B) False

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