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? 

7. Which of the following in NOT an IRS administrative material? 

9. An excerpt from I.R.C. § 6702 of the Internal Revenue Code provides as follows:  IRC § 6702 (b) Civil Penalty for Specified Frivolous Submissions.  (1) Imposition of Penalty. Except as provided in paragraph (3), any person who submits a specified frivolous submission shall pay a penalty of $5,000. (2) Specified Frivolous Submission. For purposes of this section – (A) Specified frivolous submission. The term “specified frivolous submission” means a specified submission if any portion of such submission— (i) is based on a position which the Secretary has identified as frivolous under subsection (c), or (ii) reflects a desire or delay to impede the administration of Federal tax laws. (B) Specified submission. The term “specified submission” means— (i) a request for a hearing under – (I) section 6320 (relating to notice and opportunity for hearing upon filing of notice of lien) or  (II) section 6330 (relating to notice and opportunity for hearing before levy) Which of the following statements from the statute above is a sub clause?

16. What is the highest level of authority within the Judicial Branch?