- Preparer penalties that are pertinent here are found in §6694, taxpayer penalties start with §6662. They are similar but not identical to the rules of Circular 230, nor to the AICPA’s SSTSs. Special sanctions relate to the filing of frivolous returns.
- Taxpayer and tax preparer penalties under the Code are not always identical.
- Can a taxpayer avoid an understatement penalty because of reliance on the advice of a tax professional?
- When do interest payments begin to accumulate? Can the IRS waive penalties? Interest liabilities?
- When a tax understatement is discovered, is the CPA obligated to inform the client? The IRS?
- Was there an error on Marianne’s return concerning the installment sale? What are the proper responses to the discovery of an error on a tax return?
- Recompute the 2010 – 2012 taxable income amounts regarding the installment note, by correcting the error. What now is Marianne’s capital loss carryover into 2013?
- Does the audit notice fall within the statute of limitations period?
- Review the use of Form 8275 in dealing with an ambiguous tax filing position.
Prepare a written case study analysis for the above assigned research case, minimum of 3-4 pages. The case analysis must be fully annotated with citations in proper legal form. (See writing guidelines located in Getting Started)