C-Ment Industries, Inc. is in the business of designing, manufacturing and selling concrete equipment vehicles. In 20X9, C-Ment designed and manufactured a line of concrete pumping vehicles to transfer concrete from cement mixers to specific points within a construction site. The pumping equipment is mounted on a specially modified truck chassis. Situation A C-Ment wishes to ensure that the concrete pumping vehicles are not subject to excise tax under Internal Revenue Code Sec. 4051. (1) With what level of the IRS will Wheeler have to deal? (2) With which office? Situation B Assume that C-Ment goes ahead with the sales of the concrete pumping vehicles without seeking assurance as to the excise tax consequences from the IRS. Two years later, the IRS reviews C-Ment’s excise tax returns. (1) Who determines if the return should be audited? (2) To what level of the IRS are C-Ment’s returns sent if the IRS determines that it must contact the corporation during the audit process? Situation C In discussing this case with the IRS representative, C-Ment has tried to convince the revenue agent that the concrete pumping vehicles are not subject to excise tax. Because the agent will not concede the issue, C- Ment now seeks to get a higher level of the IRS to advise the agent that “as a matter of law” the vehicles are not subject to excise tax under Code Sec. 4051. (1) What level of the IRS, if any, would make such a determination? (2) How would C-Ment go about requesting IRS participation? Situation D Assume that eventually the IRS determines that there is additional excise tax due as a result of C-Ment’s improper accounting for the concrete pumping vehicles. C-Ment wishes to seek review of this determination within the IRS. (1) With what level of the IRS must Wheeler deal for such formal review? (2) What formalities must Wheeler follow? Situation E Assume that eventually the IRS determination is upheld throughout the formal review and that C-Ment receives a bill for the tax due resulting from the deficiency. (1) What level of the IRS sends the bill to C-Ment? (2) Where can C-Ment make payment of the amount of the bill? Situation F Because of financial difficulties, C-Ment does not have the funds to pay this bill in full. (1) With what level or levels of the IRS will C-Ment deal in attempting to resolve the unpaid bill? (2) If the IRS personally meets with C-Ment to resolve the problem, who will make the contact?

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SITUATION A 1 Wheeler will have to deal with the IRS at the federal level 2 Wheeler will have to dea... View the full answer