Chapter 2, Exhibit 12
CCH Federal Taxation Comprehensive Topics 29 of 32 Appeals Administrative Process If the taxpayer and the agent do not agree, the taxpayer has several options: Request a conference in the IRS Appeals Office File a petition in the Tax Court Wait for the 90-day period to expire, pay the assessment, and start a refund suit in the District Court or the Court of Federal Claims Chapter 2, Exhibit 13
CCH Federal Taxation Comprehensive Topics 30 of 32 Taxpayer Bill of Rights The Taxpayer Bill of Rights is divided into four major categories: Taxpayer rights and IRS obligations Levy and lien provisions Proceedings by taxpayers Authority of the Tax Court Chapter 2, Exhibit 14
CCH Federal Taxation Comprehensive Topics 31 of 32 Choice of Tax Forum Jurisdiction Payment of tax Jury trial Rules of evidence Expertise of judges Publicity Legal precedent Factual precedent Statute of limitations Discovery Factors to consider in deciding whether to litigate a case and where to litigate: Chapter 2, Exhibit 15
CCH Federal Taxation Comprehensive Topics 32 of 32 Penalties Delinquency penalties Accuracy-related and fraud penalties Negligence penalty Substantial understatement of tax liability Substantial valuation misstatement penalty Substantial overstatement of pension liabilities Estate of gift tax valuation understatements Penalty for aiding understatement of tax liability Civil fraud penalty Criminal fraud penalty Estimated taxes and underpayment penalties Failure to make deposits of taxes Tax preparer penalties Chapter 2, Exhibit 16
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- Fall '14
- Taxation in the United States, CCH Federal Taxation, Federal Taxation Comprehensive Topics, Taxation Comprehensive Topics