REG - M4 - Prof Responsibilities and Fed Tax Procedures

Question 1

What is the hierarchy for Tax Authority

Answer 1

IRC - Internal Revenue Code - statute
Treasury Regulations - interpretations
IRS Revenue Rulings and Procedures - promote uniform application
IRS Private Letter Rulings
US Supreme Court Decisions
Lower Federal Court Decisions
IRS Publications/Notices/Forms
Other Sources - tax journals, articles - insights only

Question 2

Circular 230

Answer 2

IRS publication with Treasury regs governing practice before IRS
covers
rules governing the authority of a tax practitioner to practice bef IRS
duties and restrictions relating to practicing before IRS
sanctions for violation of the regulations
rules applicable to IRS disciplinary proceedings

Question 3

Circular 230 persons governed

Answer 3

Tax Attorneys
CPAs
Enrolled agents
Enrolled actuaries
Enrolled retirement plan agents
Registered tax return preparers
Other persons allowed (officer of corp or trust representing)

Question 4

When can tax practitioner charge a contingency fee?

Answer 4

IRS Audit
Claim solely for a refund or interest or penalties
a judicial proceeding arising under IRC

Question 5

Return of client records

Answer 5

Return all records client needs to comply with fed tax obligations
practitioner can retain copies