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Underpayment is defined in ยง 6664 as the correct amount of tax, less the sum of the amount of tax reported by the taxpayer on the return, plus any amount previously assessed or collected, less the amount of rebates made.

A) True
B) False

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Which of the following would lead to imposition of civil penalties?


A) violation of civil protocols
B) violation of tax laws as a result of negligence
C) violation of tax statutes due to reasonable cause
D) violation of social rules and norms

E) None of the above
F) A) and D)

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Generally, an overpayment can be refunded or credited to the person who was subject to the original tax.

A) True
B) False

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The penalty for failure to make payment of quarterly estimated income taxes is computed without any daily compounding and is not deductible.

A) True
B) False

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A fraudulent failure-to-file tax return is subject to a 25 percent monthly penalty.

A) True
B) False

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List some of the possible defenses that a taxpayer may use against a charge of criminal tax offense.

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With respect to criminal tax cases, taxp...

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If a taxpayer understates gross income by 25 percent, the IRS has a 6-year statute of limitations on assessment.

A) True
B) False

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If a taxpayer fails to file her return due to willful neglect, the minimum penalty is:


A) 25 percent or 5 months cumulative penalty
B) lesser of $205 or the full amount of taxes that are required to be shown on the return
C) 15 percent monthly penalty
D) lesser of $135 or the full amount of taxes that are required to be shown on the return

E) A) and B)
F) C) and D)

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The standard for conviction in a criminal case is establishment of:


A) guilt with some reasonable doubt
B) guilt beyond reasonable doubt
C) any guilt even though highly doubtful
D) criminal intent even though not implemented

E) B) and C)
F) A) and D)

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Assessable penalties typically are expressed as a flat dollar amount and are usually imposed on third parties, such as tax return preparers.

A) True
B) False

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The burden of proof in a fraud case is on the:


A) taxpayer
B) tax court
C) IRS
D) tax practitioner

E) None of the above
F) A) and B)

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Could a taxpayer make such a small amount of income that a tax return not be filed and still have an unlimited statute of limitations on assessment?

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Yes, a taxpayer who innocently...

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