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Identify which of the following statements is false.


A) Regular and memorandum decisions of the Tax Court are published by the government in the Tax Court of the United States Reports.
B) The citation Cristofani,97 T.C.74 (1991) indicates that the decision is a regular decision of the Tax Court.
C) The citation Estate of Newhouse,94 T.C.193 (1990) ,nonacq.1991-1 C.B.1 indicates that the IRS did not formally disagree with this 1990 Tax Court decision until 1991.
D) The Board of Tax Appeals preceded the Tax Court.

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Assume that you want to read a description of a particular area of the law,along with one or more illustrations of how that law is applied.You will not find that type of material in


A) a citator.
B) the Treasury Regulations.
C) the Cumulative Bulletin.
D) the Committee Reports.

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Final regulations can take effect on any of the following dates except


A) the effective date of the statutory language they interpret,provided they are issued within 18 months of the date of the change to the statute.
B) the date on which final regulations were proposed.
C) the date on which related temporary regulations were first published in the Federal Register.
D) the date on which they were issued in final form.

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Which regulation deals with the gift tax?


A) Reg.Sec.1.165-5
B) Reg.Sec.20.2014-5
C) Reg.Sec.25.2518-5
D) Reg.Sec.301.7002-5

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Regular and memorandum decisions have the same precedential value.

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Regular and memorandum decisions do not ...

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If the U.S.Supreme Court decides to hear an appeal of a tax case,it will grant a


A) writ of appeal.
B) writ of certiorari.
C) writ of detainer.
D) writ of habeas corpus.

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Which of the following statements about the Statements on Standards for Tax Services is true?


A) A CPA is never allowed to use a taxpayer's estimates when preparing a tax return.
B) The CPA must tell the IRS upon becoming aware that an error has been made on a past tax return.
C) The CPA may in good faith rely on information provided by the taxpayer,without verifying the reliability of that information if reasonable inquiries are made where the information furnished appears to be incorrect.
D) The CPA should not recommend that a taxpayer take a certain position if there is any doubt as to whether the position would be approved by the IRS upon audit.

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Which of the following documents is issued by the IRS to a specific taxpayer?


A) regulation
B) revenue procedure
C) letter ruling
D) information release

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C

Communicate the result to the client.The communication with the client should not result in a misunderstanding.While discussions with the client may be suitable,it is recommended by the AICPA's Statements on Standards for Tax Services that the communication be written where issues are important,unusual or complicated.Many firms require that conclusions be communicated in writing.

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Dear [Client], We are writing to communicate the results of our recent discussions regarding your tax services. As per the AICPA's Statements on Standards for Tax Services, we believe it is important to ensure that there is no misunderstanding in our communication with you. After careful consideration, we have determined that it is necessary to provide you with a written communication regarding the important, unusual, or complicated issues that have arisen during our discussions. This is in line with the recommendations of the AICPA and is also a requirement of our firm. We understand that written communication may not always be the preferred method of communication, but we believe that it is the most effective way to ensure that all important details are accurately conveyed and understood. We want to ensure that you have a clear understanding of the conclusions we have reached and the reasoning behind them. We appreciate your understanding and cooperation in this matter, and we are committed to providing you with the highest level of service and communication. If you have any questions or concerns regarding this communication, please do not hesitate to reach out to us. We are here to assist you and ensure that you have a complete understanding of the results of our discussions. Thank you for your continued trust in our firm. Sincerely, [Your Name] [Your Title] [Your Firm]

Taxpayers must pay the disputed tax prior to filing a case with the Tax Court.

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Evaluate the authorities.Choose the ones to follow when there are conflicting authorities.

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Evaluating and choosing which authoritie...

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Appeals from the U.S.Tax Court are to the Court of Appeals for the Federal Circuit.

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A revenue ruling is issued by the Internal Revenue Service only in response to a verbal inquiry by a taxpayer.

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When Congress passes a statute with language such as,"The Secretary shall prescribe such regulations as he may deem necessary," the regulations ultimately issued for that statute are


A) congressional regulations.
B) statutory regulations.
C) interpretative regulations.
D) legislative regulations.

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A tax case cannot be appealed when initiated in the


A) U) S.Court of Federal Claims.
B) U) S.Tax Court.
C) U) S.Tax Court using the small case procedures.
D) None of the above.

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Identify which of the following statements is true.


A) RIA United States Tax Reporter and CCH Standard Federal Tax Reporter are topical tax services.
B) An annotated tax service is organized by broad subject areas.
C) Annotations are summaries of IRS pronouncements and court opinions.
D) All of the above are false.

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What are some of the consequences of the small cases procedure of the Tax Court?

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The small cases procedure allo...

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The primary citation for a federal circuit court of appeals case would be


A) 40 AFTR 2d 78-1234.
B) 44 F.Supp.403.
C) 3 F.3d 134.
D) 79-2 USTC & 9693.

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C

Explain the legislative reenactment doctrine.

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Under the legislative reenactment doctri...

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Assume that the Tax Court decided an expenditure in question was deductible.The government appealed to the Fifth Circuit,which reversed the decision and held it was not deductible.No other circuits have ruled on the issue. A new case has just been filed in the Tax Court.How will the Tax Court rule if this new case is appealable to the Tenth Circuit? Would your answer be different if the case was appealable to the Fifth Circuit?

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The Golsen rule provides that the Tax Co...

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