1. On January 9, 2015, Edgardo filed his Form 1040, U.S. Individual Income Tax Return, for taxable year 2014.  On February 4, 2017, the IRS began examining Edgardo’s return and made recommendations to assert a deficiency in the amount of $5,000. The IRS assessed the deficiency on April 7, 2018. Is the IRS’s assessment legally valid?

7. Ashley is married to her husband Carlos. Last year, Ashley accidentally underreported her income to the IRS. Ashley admitted to Carlos that she underreported months later after she recognized the error. If the IRS asserts the IRC § 6662 penalty against Ashley and wishes to speak with Carlos regarding Ashley’s confession, must he comply with the IRS?

3. John Roberts is a tax protester. For several years, Roberts never filed his tax returns, but for taxable year 2022, Roberts decided to timely file his Form 1040, U.S. Individual Income Tax Return, and listed as his mailing address: 98 Warren Street, Meriden, CT 06450. Two months later, Roberts sent a letter via certified mail to the IRS which stated: “I have moved and this is my new address: 41 Bromfield Street, Boston, MA 02108. Please send me all future correspondence either to this address or my email address at: john.roberts@msn.com.” One year later, the IRS determined a deficiency with respect to John Robert’s taxable year 2022 and emailed him a copy of the Statutory Notice of Deficiency but accurately listed his new address in the body of the Notice. Is this Notice legally valid? 

2. Hector Gonzalez is a single filer and had a variety of sources of income for taxable year 2020, including, but not limited to W-2 wages, investment income, and bond interest. On April 10, 2021, Hector filed a request for an extension to file his Form 1040, Individual Income Tax Return, which was approved by the IRS on April 14, 2021. The IRS granted Hector the ability to file his return no later than October 15, 2021. Hector files his Form 1040 in accordance with the extension on September 9, 2021. Hector’s return is later audited and the IRS issues a statutory notice of deficiency on September 19, 2024. Is the SNOD legally valid? 

5. Daniel Fisk is an attorney who practices estate and tax law in Washington, D.C. and Maryland. Fisk primarily handles drafting wills and trusts for his clients, but occasionally prepares individual income tax returns and sends documents to the IRS in support of clients who are being audited. In Attorney Fisk’s communications and filings with the IRS, he does not include his PTIN. Do Attorney Fisk’s activities constitute practice before the IRS?  

10. An individual is not considered to be practicing before the IRS, unless and until, they have a valid Form 2848 or Form 8821 on file with the IRS? 

4. On October 10, the IRS Mathematical Error Program caught an error on Martin Luther’s recently filed federal income tax return. The specific error was the transposition of a number on Luther’s gross income he reported to the IRS, which resulted in an additional $700 tax due. Luther receives a notice from the IRS indicating the alleged error and he wishes to challenge it in Tax Court. Can Luther challenge the IRS’s adjustment to his tax due in the Tax Court? 

3. Jacob Wrentham, a 31-year-old single filer, has been notified by the IRS that his return is being audited. According to documentation he has received in the mail, the audit is focused solely on Jacob’s timely-filed Form 1040, Line 12. The audit of Jacob’s return is most likely a:

13. Assume the same facts as Question #9. Is either a chapter or subchapter of the Internal Revenue Code reflected in any of the answer choices? 

5. Which amendment to the U.S. Constitution allows Congress to lay and collect taxes without apportionment among the several states?