Arnold Ames, a partner in an accounting firm, discovers that one of his clients omitted a substantial amount 41. of gross income. Arnold should immediately notify his partners and the IRS.A claim for refund must be filed within three years from the date the return was filed or within three years 42. from the date the tax was paid, whichever date is later.If the taxpayer disagrees with an examiner’s findings, the taxpayer must first make an appeal to the IRS 43. before going to the courts.Barry Broom’s tax return was examined by a tax auditor who determined additional tax due of $2,400. 44. Barry does not agree with the proposed change and requests a conference with the Appeals Office. Barry is required to submit a written protest with his request to the Appeals Office.Secondary sources of authority such as tax services, citators, and legal periodicals are references that 45. explain and comment on primary sources of authority.
391Testbank©2010 CCH. All Rights Reserved. Chapter 2Regulations often define terms, clarify language used in the Code, and explain how the President believes 46. the tax laws should be interpreted.The American Institute of Certified Public Accountants (AICPA) has adopted Statements on Standards for 47. Tax Service that are enforceable against all tax practitioners.The Internal Revenue Code of 1939 replaced the piecemeal annual revenue acts.48. Revenue legislation begins in the Senate.49. The internal revenue laws were revised by the Tax Reform Act of 1986 and renamed the Internal Revenue 50. Code of 1986.Upon examination of a tax return, the IRS has the authority to impose additional taxes and penalties.51. Decisions of the U.S. Courts of Appeals and some decisions of other federal courts may be reviewed by the 52. United States Supreme Court. The Supreme Court is obligated to hear all federal tax cases that it has been requested to review.Regulations may be legislative, interpretative, and procedural, and are afforded different weight by the 53. courts.Revenue rulings are issued on the basis of Code sections and may be subsequently changed (modified) or 54. revoked to reflect subsequent law or regulation changes and court decisions.The purpose of revenue rulings is to promote uniform application of the tax law to an entire set of facts. 55. Therefore, IRS employees must follow the rulings, while taxpayers may appeal adverse return examination decisions based on these rulings.The United States Tax Court is a court of national jurisdiction.56. Both the taxpayer and the government may appeal decisions of the U.S. Tax Court or U.S. District Court to 57. the U.S. Court of Appeals.Practice before the IRS is available only for “enrolled agents.”58. The Tax Code provides criminal penalties for tax professionals that include prison time. 59.
- Fall '12
- Tax law, Taxation in the United States, internal revenue, United States Tax Court