Deck 21 Flashcards

1
Q

Primary authoritative sources does not include:

A

IRS publications

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2
Q

Listed transaction

A

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

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3
Q

More likely than not

A

> 50%

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4
Q

Reasonable Basis

A

> 20%

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5
Q

Substantial Authority

A

> 33% but less than 50%

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6
Q

Tax return preparer

A

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

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7
Q

Tax practitioner

A

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

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8
Q

Tax shelter

A

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

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9
Q

Tax preparer is required to keep records for how long?

A

3 years

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10
Q

Circular 230

A

General rules that apply to tax practitioners

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11
Q

What group can seek criminal penalties?

A

Internal Revenue Service (IRS)

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12
Q

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

A

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

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13
Q

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

A

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

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14
Q

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

A

The taxpayer

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15
Q

Which senate considers new tax legislation?

A

Finance committee

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16
Q

What does it mean to issue a “no change” report?

A

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

17
Q

Where does tax law originate?

A

House of Representatives

18
Q

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

A

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

19
Q

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

A

Appeals division; not a revenue agent

20
Q

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

A

Notice of Deficiency