In a U.S. Tax Court case, which of the following is true?The Tax Court may evaluate the entire return, not just the issue being contestedThe Tax Court judges are generalists, meaning that they do not necessarilyspecialize in tax casesTax Court cases are presented to a panel of 3 judgesTaxpayers can request a jury trial in a Tax Court

This implies that the court will not be restricted to the particular issue at hand if a taxpayer…

Answered: In a U.S. Tax Court case, which of the…

Individual Income Taxes

43rd Edition

ISBN:9780357109731

Author:Hoffman

Publisher:Hoffman

Chapter2: Working With The Tax Law

Section: Chapter Questions

Problem 20DQ

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Similar questions

If a U.S. Tax Court agrees with the taxpayer on appeal that the IRS position was largely unjustified, which of the following is correct? The taxpayer must still pay administrative and litigation costs. The taxpayer may recover administrative but not litigation costs. The taxpayer may recover litigation but not administrative costs. To be eligible to recover some of the administrative and litigation costs, the taxpayer must have tried to resolve the case administratively, including going through the appeals process, and must have given the IRS the information necessary to resolve the case. None of the above.
You are assisting a client with a transaction that produces a most favorable tax result. The client told you the outcome is dependent on one court case. What should you do? a. Nothing. Your due diligence obligations allow you to rely in good faith on information furnished to you by the client; you are permitted to rely on the client's judgment. 6. Check with the client's auditor to ensure the numbers are valid; then you can recalculate intended tax benefits. c. Help the client by getting a head start on the tax return presentation of the transaction; the better the presentation, the less likely it will be audited by the IRS. d. Analyze the case to make sure the holding has not been reversed, the client's facts are similar to those described in the case, and the law cited in the case is still valid.
If you wish to contest a tax deficiency, but pay the tax and file a claim and that claim is denied and now you file suit, you must file your petition in: a. US Court of Appeals b. US Supreme Court c. 14th judicial district court (Calcasieu Parish) d. US Tax Court e. US District Court
The following is true of a Circuit of Appeals: a. The taxpayer who originated his claim in a US District Court may be appeal decision to any Circuit Court of Appeals the taxpayer chooses b. The Court of Appeals may affirm the lower court decision, reverse the decision or retry the facts on appeal. c. The Circuit Courts of Appeal follow stare decisis and are bound by their previous decisions, but they are not required to follow the decisions of other Circuits d. All of the above.
Pursuant to the Golsen Rule: a. the Tax Court must follow all Circuit Court of Appeals decisions. b. the Tax Court must follow decisions of the Court of Appeals for the Circuit in which the taxpayer's appeal may be filed. c. the Tax Court may adopt its own interpretation of the tax law, if the taxpayer's Circuit Court has not ruled on the matter. d. Two of the above.
You and Jackie are arguing whether tax laws can be retroactive in its application. Jackie noted that they can only be prospective but you take the stand that it may retroactive. Which of the following would be the least fit example you could give? A. tax laws imposing business tax B. tax laws implementing riles and regulations that are remedial in nature C. tax circulars that are intended for internal purposes of BIR D. tax memoranda that are interpretative in nature
You and Sunny are arguing whether tax laws can be retroactive in its application. Sunny noted that they can only be prospective but you take the stand that it may retroactive. 1. Which of the following would be the least fit example you could give? A. tax laws implementing riles and regulations that are remedial in nature B. tax memoranda that are interpretative in nature C. tax laws imposing business tax D. tax circulars that are intended for internal purposes of BIR
The concept of reverse onus, as it relates to taxation in Canada, suggests: Select one: O a. We should refrain from exercising tax avoidance O b. We should engage in tax evasion O C. We may have to go through an appeal process, firstly with CRA (Canada Revenue Agency) and possibly through the courts, if we disagree with a reassessment O d. We are not required to comply with a reassessment from CRA because a court ruling will be required firstly
Jamareo has found a "favorable" authority directly on point for his tax question. Required: a. If the authority is an administrative authority, which specific type of authority would he prefer to answer his question b. Which administrative authority would he least prefer to answer his question? Complete this question by entering your answers in the tabs below. Required A Required B If the authority is an administrative authority, which specific type of authority would he prefer to answer his question? M Revenue Ruling Private Letter Ruling Revenue Procedure Treasury Department Regulation Required A Required B >
Tax preparers often have a difference of opinion with their clients as to how some transactions should be treated on a tax return. If a client of yours does not wish to report information on their tax return that you feel should be reported, how would you handle the situation? Write in at least 300 words with two scholarly sources.
Indicate whether the following statements are "True" or "False" regarding letter rulings. a. Letter rulings have the force and effect of law and provide guidance and support for taxpayers in similar transactions. b. A letter ruling represents the current opinion of the IRS on the tax consequences of a transaction with a given set of facts. c. Letter rulings not only help promote a uniform application of the tax laws but also may reduce the potential for litigation or disputes with IRS agent
Does the IRS acquiesce in decisions of U.S. district courts? C O A. Yes. However, the IRS can only acquiesce in a federal court decision that is adverse to the IRS if they feel the taxpayer is defrauding their tax liability. O B. Yes. The IRS can acquiesce in any federal court decision that is adverse to the IRS if the IRS decides to do so. O C. Yes. The IRS can acquiesce in any federal court decision that is adverse to the IRS if the opinions of the IRS commissioner is not taken into account. O D. No. The IRS has no grounds to acquiesce in any federal court decision. They can only acquiesce in regular Tax court decisions.

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