Deck 21 Flashcards Preview

Regulation > Deck 21 > Flashcards

Flashcards in Deck 21 Deck (20):
1

Primary authoritative sources does not include:

IRS publications

2

Listed transaction

Identified by the Secretary of the U.S. Treasury Department; tax avoidance transaction

3

More likely than not

>50%

4

Reasonable Basis

>20%

5

Substantial Authority

>33% but less than 50%

6

Tax return preparer

Any person wo prepares for compensation or employs a person to prepare for compensation or any claim for refund

7

Tax practitioner

Individuals who practice before the IRS: attorneys, CPAs, enrolled agents

8

Tax shelter

Plan or arrangement with a significant purpose to have tax avoidance or tax evasion

9

Tax preparer is required to keep records for how long?

3 years

10

Circular 230

General rules that apply to tax practitioners

11

What group can seek criminal penalties?

Internal Revenue Service (IRS)

12

The penalty for failure to file a tax return by the due date is:

5% per month or fraction of month on the amount of tax shown as due on the return

13

The penalty for failure to pay by the due date is:

1/2% per month based on the amount due on the return

14

In civil tax cases, who bears the burden of the proof?

The taxpayer

15

Which senate considers new tax legislation?

Finance committee

16

What does it mean to issue a "no change" report?

The IRS generally does not reopen the examination except in cases involving fraud or other similar misrepresentation

17

Where does tax law originate?

House of Representatives

18

What groups of taxpayers are more subject to audit under the Discriminant Inventory Function System (DIF)?

Individuals with gross income greater than $100,000; self-employed individuals; and cash businesses

19

Who's can settle an unresolved issue based on the probability of winning the case in court?

Appeals division; not a revenue agent

20

What does a taxpayer need to take a case to the U.S. Tax Court?

Notice of Deficiency