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Tax Compliance, the IRS, and Tax Authorities

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Question;Tax Compliance, the IRS, and Tax Authorities;True / False Questions;1.;Corporations are required to file a tax return annually;regardless of their taxable income.;True False;2.;The tax return filing requirements for individual taxpayers;only depend on the taxpayer's filing status.;True False;3.;If a taxpayer is due a refund, she does not have to file a;tax return.;True False;4.;If April 15th falls on a Saturday, the due date for;individual tax returns will be on Monday, April 17th.;True False;5.;If a taxpayer is unable to file a tax return by its original;due date, the taxpayer can request an automatic 9-month extension to file the;return.;True False;6.;An extension to file a tax return does not extend the due;date for tax payments.;True False;7.;The statute of limitations for IRS assessment generally ends;four years after the date a tax return is filed.;True False;8.;For fraudulent tax returns, the statute of limitations for;IRS assessment is ten years.;True False;9.;The IRS DIF system checks each tax return for mathematical;mistakes.;True False;10.;Joel claimed a high amount of charitable contributions as a;deduction on his 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.;True False;11.;Office examinations are the most common type of IRS audit.;True False;12.;The three basic types of IRS examinations are computer;exams, office exams, and business exams.;True False;13.;The "30-day" letter gives the taxpayer the;opportunity to request an appeals conference or agree to the proposed IRS;adjustment.;True False;14.;The "90-day" letter gives the taxpayer the;opportunity to pay the proposed tax adjustment or file a petition in the U.S.;District Court to hear the case.;True False;15.;If a taxpayer has little cash and a very technical tax case;that she feels very strongly that the tax rules are "on her side,;she should prefer to have her case tried in the U.S. Tax Court.;True False;16.;In researching a tax issue, Eric finds that the U.S. Circuit;Court of Appeals for the Federal Circuit previously has ruled in favor of his;tax position, whereas the 11th Circuit (Eric's circuit) previously has ruled;against his tax position. If Eric is contemplating litigating his tax position;with the IRS, he should prefer to have his case first tried by the U.S. Tax;Court.;True False;17.;If a taxpayer loses a case at the Circuit Court level, he is;granted an automatic appeal hearing with the Supreme Court.;True False;18.;Secondary authorities are official sources of the tax law;with a lesser "weight" than primary authorities.;True False;19.;Revenue rulings and revenue procedures are examples of;primary authorities.;True False;20.;The Internal Revenue Code and tax treaties are examples of;statutory authorities.;True False;21.;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 the U.S. Court of Federal Claims.;True False;22.;Temporary Regulations have more authoritative weight than;revenue rulings.;True False;23.;Proposed and Temporary Regulations have the same;authoritative weight.;True False;24.;An acquiescence indicates that the IRS lost a court case and;that it has decided to follow the court's ruling in the future.;True False;25.;The Internal Revenue Code of 1986 is the name of the current;tax code.;True False;26.;As required by the Constitution, all tax bills are supposed;to originate in the House of Representatives.;True False;27.;The Senate Ways and Means Committee is in charge of drafting;tax bills in the U.S. Senate.;True False;28.;Closed facts are especially conducive to tax planning.;True False;29.;Of the two basic types of tax services, beginning tax;researchers often prefer topical tax services.;True False;30.;In researching a question of fact, the researcher will focus;her efforts on identifying authorities with fact patterns similar to her;client's facts.;True False;31.;Under the Statement on Standards for Tax Services, a CPA may;recommend a tax return position if the position is frivolous and the position;is not disclosed on the tax return.;True False;32.;In general, a CPA will satisfy his professional;responsibilities under the Statement on Standards for Tax Services when;recommending a tax return position if he complies with the standards imposed by;the applicable tax authority.;True False;33.;Under the tax law, taxpayers may be subject to both civil;and criminal penalties for underpaying their tax liability (e.g., due to;fraud).;True False;34.;A taxpayer can avoid an underpayment penalty if there is;substantial authority that supports her tax return position.;True False;35.;If the IRS assesses additional tax upon audit, a taxpayer;may be subject to interest and penalties on the underpayment.;True False;Multiple Choice Questions;36.;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 these.;37.;If Paula requests an extension to file her tax return, the;latest she could file her return without penalty is;A.;September 15th.;B.;October 15th.;C.;August 15th.;D.;November 15th.;E.;None of these.;38.;If Lindley requests an extension to file her tax return, the;latest she could pay her tax due without penalty is;A.;April 15th.;B.;October 15th.;C.;August 15th.;D.;November 15th.;E.;None of these.;39.;Corporations are required to file a tax return only if their;taxable income is greater than;A.;$0.;B.;$1,000.;C.;$600.;D.;$750.;E.;None of these. Corporations are always required to file a;tax return.;40.;This year April 15th falls on a Saturday. Individual tax;returns will be due on;A.;April 14th.;B.;April 15th.;C.;April 16th.;D.;April 17th.;E.;None of these.;41.;Dominic earned $1,500 this year, and his employer withheld;$200 of federal income tax from his salary. Assuming that Dominic will have;zero tax liability this year, he;A.;is required to file a tax return.;B.;is not required to file a tax return but should file a;return anyway.;C.;is required to file a tax return but should not file because;he owes no tax.;D.;is not required to file a tax return and should not file a;return.;E.;None of these.;42.;Greg earned $20,500 this year and had $1,500 of federal;income taxes withheld from his salary. Assuming that Greg will have a total tax;liability of $1,000 (and thus will receive a $500) refund, he;A.;is required to file a tax return.;B.;is not required to file a tax return but should file a;return anyway.;C.;is required to file a tax return but should not file because;he owes no tax.;D.;is not required to file a tax return and should not file a;return.;E.;None of these.;43.;Bill filed his 2014 tax return on March 15th, 2015. The;statute of limitations for IRS assessment on Bill's 2014 tax return should end;A.;March 15th, 2017.;B.;April 15th, 2017.;C.;March 15th, 2018.;D.;April 15th, 2018.;E.;None of these.;44.;Henry filed his 2014 tax return on May 15th, 2015. The;statute of limitations for IRS assessment on Henry's 2014 tax return should;end;A.;May 15th, 2017.;B.;April 15th, 2017.;C.;May 15th, 2018.;D.;April 15th, 2018.;E.;None of these.;45.;Allen filed his 2014 tax return on May 15th, 2015 and;underreported his gross income by 30 percent. Assuming Allen's underreporting;is not due to fraud, the statute of limitations for IRS assessment on Allen's;2013 tax return should end;A.;May 15th, 2017.;B.;April 15th, 2017.;C.;May 15th, 2018.;D.;April 15th, 2018.;E.;None of these.;46.;Andy filed a fraudulent 2014 tax return on May 1, 2015. The;statute of limitations for IRS assessment on Andy's 2014 tax return should end;A.;May 1st, 2017.;B.;April 15th, 2017.;C.;May 1st, 2018.;D.;April 15th, 2018.;E.;None of these.;47.;Martin has never filed a 2014 tax return despite earning;approximately $20,000 providing landscaping work in the community. When does;the statute of limitations expire for Martin's 2014 tax return?;A.;2017.;B.;2018.;C.;2021.;D.;2022.;E.;None of these.;48.;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 these.;49.;Leslie made a mathematical mistake in computing her tax;liability. Which audit program will likely catch Leslie's mistake?;A.;DIF system.;B.;Mathematical correction.;C.;Document perfection.;D.;Information matching.;E.;None of these.;50.;Tyrone claimed a large amount of charitable contributions as;a tax deduction relative to taxpayers with similar levels of income. If;Tyrone's tax return is chosen for audit because of his large charitable;contributions, which audit program likely identified Tyrone's tax return for;audit?;A.;DIF system.;B.;Deduction detective.;C.;Document perfection.;D.;Information matching.;E.;None of these.;51.;Ramon's tax return was randomly selected for audit. Which;IRS program likely selected Ramon's return for audit?;A.;DIF system.;B.;National Research Program.;C.;Document perfection.;D.;Information matching.;E.;None of these.;52.;Which of the following audits is the most common and;typically less comprehensive?;A.;Correspondence.;B.;Random.;C.;Office.;D.;Field.;E.;None of these.;53.;Which of the following audits is the least common, broadest;in scope, and typically most complex?;A.;Correspondence.;B.;Targeted.;C.;Office.;D.;Field.;E.;None of these.;54.;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;A.;30-day letter.;B.;90-day letter.;C.;Appeals letter.;D.;Tax adjustment letter.;E.;None of these.;55.;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 these.;56.;Which of the following courts is the only court that;provides for a jury trial?;A.;Tax Court.;B.;U.S. Court of Federal Claims.;C.;U.S. District Court.;D.;U.S. Circuit Court of Appeals.;E.;None of these.;57.;Lavonda discovered that the 5th Circuit (where Lavonda;resides) 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;A.;Tax Court only.;B.;U.S. Court of Federal Claims only.;C.;U.S. District Court only.;D.;Tax Court or the U.S. District Court.;E.;Tax Court or the U.S. Court of Federal Claims.;58.;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;A.;Tax Court only.;B.;U.S. Court of Federal Claims only.;C.;U.S. District Court only.;D.;Tax Court or the U.S. District Court.;E.;Tax Court or the U.S. Court of Federal Claims.;59.;Rowanda could not settle 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.;U.S. Tax Court.;E.;None of these.;60.;Which of the following is not considered a primary;authority?;A.;Tax Court case;B.;Regulation;C.;Revenue ruling;D.;Tax service;E.;None of these.;61.;Which of the following is not considered a secondary;authority?;A.;Text book;B.;Private letter ruling;C.;Tax article;D.;Tax service;E.;None of these.;62.;Which of the following has the highest authoritative weight?;A.;Text book.;B.;Private letter ruling.;C.;Revenue ruling.;D.;Tax service.;E.;Tax article.;63.;Which of the following has the highest authoritative weight?;A.;Legislative regulation.;B.;Private letter ruling.;C.;Revenue ruling.;D.;Action on decision.;E.;Revenue procedure.;64.;Josephine is considering taking a 6 month rotation in Paris;for her job. Which type of authority may be especially helpful in determining;the tax consequences of Josephine's job in Paris?;A.;Determination letter.;B.;Private letter ruling.;C.;Tax treaty.;D.;Regulation.;E.;Revenue procedure.;65.;Generally, code sections are arranged (grouped together);A.;chronologically;B.;by topic;C.;randomly;D.;by length;E.;None of these.;66.;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.;67.;Which judicial doctrine means that a court will rule;consistently with its previous rulings and the rulings of higher courts with;appellate jurisdiction?;A.;judicial hierarchy;B.;the Goldman rule;C.;judicial consistency;D.;stare decisis;E.;None of these;68.;The regulation with the lowest authoritative weight is the;A.;procedural regulation;B.;interpretative regulation;C.;proposed regulation;D.;legislative regulation;E.;None of these;69.;Princess, who resides in the 2nd Circuit, recently found a;circuit court case that is favorable to her 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 these;70.;Jaime recently found a "favorable" trial level;court opinion directly on point for her tax question. Which trial level court;would she prefer to have issued the opinion?;A.;Tax Court;B.;District Court;C.;Circuit Court;D.;Divorce Court;E.;None of these;71.;Which of the following committees typically initiates for;tax legislation?;A.;House Ways and Means Committee;B.;Joint Conference Committee;C.;Senate Finance Committee;D.;Senate Tax Committee;E.;None of these.;72.;Edie would like to better understand a new code section;enacted four weeks ago. Which of the following authorities will help Edie;understand the newly enacted code section?;A.;IRS regulations;B.;U.S. Tax Court cases;C.;Committee reports;D.;IRS revenue rulings;E.;None of these.;73.;If the President vetoes tax legislation, Congress;A.;cannot override the President's veto.;B.;can override the President's veto with a 50 percent positive;vote in the House and Senate.;C.;can override the President's veto with a 2/3rd positive vote;in the House and Senate.;D.;can override the President's veto with a 75 percent positive;vote in the House and Senate.;E.;None of these.;74.;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;A.;open facts.;B.;new facts.;C.;old facts.;D.;closed facts.;E.;None of these.;75.;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 these.;76.;Which of the following types of tax services are arranged by;code section?;A.;legal tax service.;B.;annotated tax service.;C.;professional tax service.;D.;topical tax service.;E.;None of these.;77.;Which of the following is not a common tool used in;conducting tax research?;A.;citator.;B.;annotated tax service.;C.;topical tax service.;D.;keyword search.;E.;None of these.;78.;Which of the following is not a source of a tax;practitioner's professional responsibilities?;A.;AICPA Code of Professional Conduct.;B.;Statements on Standards for Tax Services.;C.;Circular 230.;D.;State Board of Accountancy statutes.;E.;None of these.;79.;According to Statement on Standards for Tax Services No. 1;a tax practitioner can recommend a tax return position;A.;if the position is frivolous and disclosed on the tax;return.;B.;if the position complies with the standards imposed by the;applicable tax authority.;C.;only if the position meets the "more likely than;not" standard.;D.;only if the position meets the "clear and convincing;evidence" standard.;E.;None of these.;80.;Circular 230 was issued by;A.;AICPA.;B.;State Boards of Accountancy.;C.;American Bar Association.;D.;IRS.;E.;None of these.;81.;Which of the following is a false statement? A taxpayer;filing a fraudulent tax return;A.;is potentially subject to criminal penalties.;B.;is potentially subject to civil penalties.;C.;is potentially subject to fines and a prison sentence.;D.;will have an unlimited statute of limitations for the;fraudulent tax return.;E.;None of these.;82.;For which of the following tax violations is a civil penalty;not imposed on taxpayers?;A.;failure to file a tax return.;B.;failure to pay tax owed.;C.;fraud.;D.;failure to make estimated tax payments.;E.;None of these.;83.;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 these.;84.;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 the position is not frivolous and disclosed on the tax;return.;D.;if the position has a reasonable basis and is disclosed on;the tax return.;E.;None of these.;85.;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.;tax return.;E.;None of these.;86.;A tax practitioner can avoid IRS penalty relating to a tax;return position;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 these.;87.;A tax practitioner can avoid IRS penalty relating to a tax;return position;A.;only if the position has a more likely than not chance of;being sustained by the IRS or courts.;B.;if the position has a realistic possibility of being;sustained by the IRS or courts.;C.;if there is not substantial authority to support the;position.;D.;if the position has a reasonable basis and is disclosed on;the tax return.;E.;None of these.;Essay Questions;88.;Tina has a very complex tax return and it looks like she;will not be able to file her tax return by its due date. When is her tax return;due? What are Tina's options for paying her tax due and filing her tax return;this year? What are the consequences if Tina does not file or pay her tax;timely? Be specific.;89.;For the following taxpayers indicate whether the taxpayer;should file a tax return and why.;a. Robert earned $50,000 this year as a staff accountant.;His estimated tax liability is $4,500, and he expects to receive a $500 tax;refund.;b. Amy earned $4,000 this year working part-time. She will;have no federal tax liability and has not made any federal tax payments.;c. Ty earned $2,500 this summer and had $200 of federal;taxes withheld from his paycheck. He will have no federal tax liability this;year.;d. Startup Corporation had a $50,000 loss this year.;e. The Walker Family Trust earned $500 of income this year.;90.;For the 2014 tax returns, indicate when the statute of;limitation expires and why.;a. Phoenix filed his tax return on February 28, 2015.;b. Jill and Randy filed their tax return on August 16, 2015.;c. Although required to file, Catherine chose not to file a;tax return this year because she was expecting a tax refund and could not pull;together all the information needed to file the return.;d. Jerry filed his tax return on May 22, 2015 but has;accidentally underreported his taxable income by 30%.;91.;For the 2014 tax returns, indicate when the statute of;limitation expires and why.;a. Simon filed his tax return on April 10, 2015.;b. Billy and Barbara filed their tax returns late on;December 1, 2015.;c. Pearson earns a living through various illegal;activities. He filed his tax return on March 14, 2015 but did not report his;illegal income on his tax return.;d. Luther filed his tax return on July 17, 2015 but has;accidentally underreported his taxable gross income by 20%.;92.;For the following tax returns, identify the method the IRS;likely used to select the return for audit.;a. Dan made a mistake in adding his income on his tax;return.;b. Juanita failed to report her salary from her 2nd job on her;tax return.;c. Michael and Venita deducted a relatively large amount of;travel expenses on their tax return for their business. The travel expense is;large relative to other taxpayers in similar businesses with similar levels of;income.;d. Paul and Melissa recently went through a very nasty;divorce. One of the issues was Paul's less than forthright accounting of his;income in determining the appropriate level of alimony.;93.;For the following tax returns, identify which of the three;audit types will most likely be utilized.;a. The IRS selected Don's return for audit because of his;high itemized deductions. The IRS would like documentation of these deductions.;b. Large Public Corporation is a very large publicly traded;corporation. It is involved in many complex transactions that have significant;tax ramifications.;c. George and Barbara operate a small business out of their;home. The IRS has identified a couple of issues that may relate to their;business.;d. The IRS selected Bill and Hillary's tax return for review;because of some of their investment;sales. They would like a better understanding of the transactions and;parties involved.;94.;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.;95.;Mel recently received a 30-day letter from the IRS. Although;his tax return being audited has several potential large issues (potential tax;consequences of $70,000 - $80,000), the IRS agent auditing his return only;identified one item that will require a more modest adjustment ($10,000). Mel;feels strongly that the $10,000 adjustment would not hold in court and was;surprised that the IRS agent did not identify some of the other potential;larger issues. What are Mel's choices with the 30 day letter and what factors;should influence his decisions?;96.;Kim has decided to go to litigate a tax issue with the IRS.;Describe the trial level courts that Kim may use to litigate the case.;97.;For the following taxpayers, please recommend the most;advantageous trial level court(s) to litigate a tax issue with the IRS.;a. Joe is litigating a tax issue with the IRS that is;considered a question of fact (i.e., the answers depends on the facts of the;case). There is not a lot of authority on point for this case but Joe has a;very appealing story to justify his position that is likely to be viewed;sympathetically by his peers.;b. The Circuit Court of Appeals for the Federal Circuit;recently issued an opinion that is very favorable to the issue that Jesse plans;to litigate with the IRS.;c. The Circuit Court of Appeals for the Federal Circuit;recently issued an opinion that is not favorable to the issue that Hank plans;to litigate with the IRS.;d. The 7th Circuit (where Elizabeth resides) recently issued;an opinion that is very favorable to the issue that Elizabeth plans to litigate;with the IRS.;98.;A client has recently learned of a recently proposed tax;bill that would increase the tax rates on investment gains by 5 percent. The;President does not support this increase. Please describe for your client the;process by which new tax legislation is created and how the President's;disapproval may influence the enactment of the bill.;99.;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.;100.;Carey was researching a tax issue and located what appears;to be a favorable IRS regulation. He knows that regulations serve different;purposes and are issued in different forms. Which purpose and which form of;regulation would provide Carey the most confidence that he has found an;authority that carries a lot of weight for the long term? How could Carey check;the status of this regulation?;101.;Campbell was researching a tax issue and found a favorable;Tax Court opinion and an IRC Code Section that appears to answer the question.;Is she finished with the research process? If so, why? If not, what must she;do?;102.;Roddy was researching an issue and found a favorable Tax;Court decision that addresses his issue. He also determined that there was a;nonacquiescence for the case. Who issued the nonacquiescence? What is it? What;does it mean and how would it affect Roddy's reliance on the court case?;103.;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.;104.;Rebecca is at a loss. A new tax law was recently passed, and;she needs to get a better understanding of why the tax law was passed and the;intent of the law from an official authority. Describe what authorities may be;especially helpful to Rebecca and why she can't find many authorities that;discuss the new law.;105.;Lakeisha, a 1st 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?;106.;Kodak is a beginning tax researcher. He knows that the 1st;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.;107.;Caitlin is a tax manager for an accounting firm, and Duff is;a first year staff accountant. Describe the differences in the manner in which;Caitlin and Duff may identify research issues and in general how one may;identify research questions.;108.;Lindy, a tax intern, is beginning her 1st tax research case;for her employer. Her manager has given her a basic understanding of the facts;and has identified the basic research question. Lindy is now ready to begin;searching for relevant tax authorities. Describe the different types of;research tools available to help a tax researcher locate relevant authority and;identify which type may be especially useful for Lindy.;109.;Hong, an introductory tax student, is beginning his 1st;research project. He has a complete understanding of the relevant facts for his;project and has identified the initial research questions. He is now ready to;begin using a tax service to identify relevant authorities. What are some;suggestions for him on how to use tax services to identify relevant;authorities?;110.;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.;111.;Nolene suspects that one of her new clients may be;intentionally underreporting his taxable income. What are the potential;ramifications to her client of this behavior? What are the consequences to;Nolene if she assists the client in underreporting income? Any advice for;Nolene?;112.;Houston has found conflicting authorities that address a;research question for one of his clients. The majority of the authorities;provide a favorable answer for his client. Nonetheless, there are several;authorities that provide an unfavorable answer. Houston estimates that if the;client takes the more favorable position on its tax return that there is;approximately a 60 percent chance that the position will be sustained upon;audit or judicial proceeding. If the client takes this position on its tax;return, will Houston be subject to penalty? Will the client potentially be;subject to penalty?

 

Paper#38052 | Written in 18-Jul-2015

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