Boris Newman is being audited by the IRS for a transaction he entered into which resulted in a refund in excess of $2.5 million. Boris is seeking Appeals consideration. Can Boris have his case heard by Appeals?

Ulysses Thomas was audited by the IRS in 2022. During the audit, Ulysses filed a formal written protest challenging the IRS’s position and requesting Appeals consideration. Ulysses’ case was heard by Appeals, but Appeals found that the IRS’s determinations were correct and that there were no hazards of litigation to justify settling in favor of the taxpayer. A statutory notice of deficiency was issued, and Ulysses immediately petitioned the Tax Court. Ulysses now wishes to have his case heard by the Independent Office of Appeals. Is Ulysses entitled to Appeals consideration? 

Which of the following is not a requirement for written advice under Circular 230, § 10.37?

Does the IRS have the ability to assert FBAR penalties? 

In a BBA Partnership Audit, the IRS may communicate with: 

4. When the IRS enters into collection proceedings against a taxpayer, the Federal Tax Lien attaches to what property? 

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?