Under what circumstances would a CPA be found liable for a preparer penalty when he or she has not actually prepared the return

1) Under what circumstances would a CPA be found liable for a preparer penalty when he or she has not actually prepared the return?

2) What are the three(3) methods of proof that the IRS would use to show the taxpayer has understated his or her income?

3) Distinguish the statue of limitations for criminal versus civil liability?

4) What is meant by the term “DIF Score”.

5) Joe, a resident of Boston, mails his return to the IRS service center in New York on April 15. April 15 is Patriots Day, an official holiday in Massachusetts. Joe pays $1,000 with the return. The return is received by the New York service center on April 18. What is Joe’s penalty, if any, for failure to timely file his return.

6) John, a calendar year taxpayer, filed his 2006 income tax return on October 10, 2007,paying an amount due of $1,000. On April 2, 2007 John filed an automatic extension of time in which to file the return. No other extensions were filed. Determine how much return John must pay.

7) Individual X files his form 1040 putting only -000- on the tax return where correct figures should appear. This return is otherwise properly completed. Has X filed an income tax return for purposes of the criminal penalty for failure to file a return?

8) Mr. X is outside the United States on April 15, 2007. As a matter of law, what is the longest extension of time he may receive to file his 2006 return?

9) If a taxpayer has not received her 90 day letter, how might she toll interest on a proposed deficiency while still maintaining her right to sue in Tax court? How would your answer change is she had her 90 day letter in hand?

10) From the perspective of the statue of limitations, why might a taxpayer file Form 1040X to claim a refund rather than file a Form 1045 to obtain the refund?

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