1. If a taxpayer files a fraudulent return, what is the statute of limitations on assessment? 2....
Question:
1. If a taxpayer files a fraudulent return, what is the statute of limitations on assessment?
2. When is there a six year statute of limitations on assessment?
3. Who signs a Form 872, Extension of Statute of limitations on Assessment?
4. What is an ex parte contact for the Independent Office of Appeals (Appeals)?
5. When is Appeals primary role in reviewing cases?
7. What are substantive grounds for challenging an IRS summons?
8. What is the difference between a compliance check and an audit?
9. What are the operating Divisions of the Internal Revenue Service and their respective functions?
10. What is the role of the Associate Chief Counsel offices within the Office of Chief Counsel?
11. When should you consider a Taxpayer Assistance Order for your clients?
12. Under Circular 230 what is a practitioner's duties regarding reliance on third party information in taking a position on a tax return?
13. What standard(s) must exist for a practitioner to advocate a position on a tax return?
14. When may a FOIA request help your client?
15. What is the relationship between FOIA and I.R.C. section 6103?
16. What is a John Doe Summons and how and/or when are they used?
17. What are the rules governing a third party summons?
18. What is an IDR and how is it used?
19. What happens if a party refuses to comply with an IRS summons?
20. What is the standard statute of limitations (SOL) for assessing tax on an individual's Form 1040?
21. What are some methods the IRS uses to determine unreported income?
22. How does the IRC define return preparer?
23. What are the advantages of pre-appeals conferences?
24. What are the three principal forms of examination conducted by the IRS?
25. What is the 30-day letter and what is the 90-day letter?
Federal Taxation 2016 Comprehensive
ISBN: 9780134104379
29th Edition
Authors: Thomas R. Pope, Timothy J. Rupert, Kenneth E. Anderson