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[LO1] Ahmed does not have enough cash on hand
to pay his taxes. He was excited to hear
that he can request an extension to file his tax return. Does this solve his problem? What are the ramifications if he doesn’t pay
his tax liability by April 15?

[LO1] Molto Stancha Corporation
had zero earnings this fiscal year; in fact, they lost money. Must they file a
tax return?

[LO1] The estate of Monique
Chablis earned $450 of income this year. Is the estate required to file an
income tax return?

[LO1] Jamarcus, a full-time
student, earned $2,500 this year from a summer job. He had no other income this year and will
have zero federal income tax liability this year. His employer withheld $300 of federal income
tax from his summer pay. Is Jamarcus
required to file a tax return? Should
Jamarcus file a tax return?

[LO1] Shane has never filed a
tax return despite earning excessive sums of money as a gambler. When does the statute of limitations expire
for the years in which Shane has not filed a tax return?

[LO1] Latoya filed her tax
return on February 10th this year. When
will the statute of limitations expire for this tax return?

[LO1] Using the facts from the previous problem,
how would your answer change if Latoya understated her income by 40 percent?
How would your answer change if Latoya intentionally failed to report as
taxable income any cash payments she received from her clients.

[LO2] Paula could not reach an agreement with
the IRS at her appeals conference and has just received a 90-day letter. If she wants to litigate the issue but does
not have sufficient cash to pay the proposed deficiency, what is her best court

[LO2] In choosing a trial-level
court, how should a court’s previous rulings influence the choice? How should circuit court rulings influence
the taxpayer’s choice of a trial-level court?

[LO2] Sophia recently won a tax
case litigated in the 7th Circuit. She
recently heard that the Supreme Court denied the writ of certiorari. Should she be happy or not, and why?

[LO2] Campbell’s tax return was
audited because she failed to report interest she earned on her tax
return. What IRS audit selection method
identified her tax return?

[LO2] Yong’s tax return was
audited because he calculated his tax liability incorrectly. What IRS audit procedure identified his tax
return for audit?

[LO2] Randy deducted a high
level of itemized deductions two years ago relative to his income level. He recently received an IRS notice requesting
documentation for his itemized deductions.
What audit procedure likely identified his tax return for audit?

[LO2] Jackie has a corporate
client that has recently received a 30 day notice from the IRS with a $100,000
tax assessment. Her client is
considering requesting an appeals conference to contest the assessment. What factors should Jackie advise her client
to consider before requesting an appeals conference?

[LO2] The IRS recently
completed an audit of Shea’s tax return and assessed $15,000 additional
tax. Shea requested an appeals
conference but was unable to settle the case at the conference. She is contemplating which trial court to
choose to hear her case. Provide her a
recommendation based on the following alternative facts.

Shea resides in the 2nd
Circuit, and the 2nd Circuit has recently ruled against the position Shea is

The Federal Circuit Court of
Appeals has recently ruled in favor of Shea’s position.

The issue being litigated
involves a question of fact. Shea has a
very appealing story to tell but little favorable case law to support her

The issue being litigated is
highly technical, and Shea believes strongly in her interpretation of the law.

Shea is a local elected
official and would prefer to minimize any local publicity regarding the case.

[LO3] Juanita, a Texas resident
(5th Circuit), is researching a tax question and finds a 5th Circuit case
ruling that is favorable and a 9th Circuit case that is unfavorable. Which circuit case has more “authoritative
weight” and why? How would your answer
change if Juanita were a Kentucky resident (6th Circuit)?

[LO3] Faith, a resident of Florida (11th Circuit) recently found a circuit
court case that is favorable to her research question. Which two circuits would she prefer to have
issued the opinion?(1)
[LO3] Robert has found a
“favorable” authority directly on point for his tax question. If the authority is a court case, which court
would he prefer to have issued the opinion?
Which court would he least prefer to have issued the opinion?(1)
[LO3] Jamareo has found a
“favorable” authority directly on point for his tax question. If the authority is an administrative
authority, which specific type of authority would he prefer to answer his
question? Which administrative authority
would he least prefer to answer his question?

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