offers in compromise by jolinmilioncherie


									                          Chapter 26

              Tax Practice And Ethics

               Comprehensive Volume

                       Copyright ©2010 Cengage Learning

Comprehensive Volume                                      C26 - 1
          Tax Administration (slide 1 of 3)
    • The IRS is responsible for administration and
      enforcement of the tax laws
        – Provides info to taxpayers through publications and
          forms with instructions so taxpayers can comply with
          the tax law
        – Identifies delinquent tax payments
        – Carries out assessment and collection procedures

Comprehensive Volume                                             C26 - 2
          Tax Administration (slide 2 of 3)
    • In meeting its responsibilities, the IRS conducts
      audits of selected tax returns
        – About 1% of all individual tax returns are audited each
        – Certain tax returns, such as those for high income
          individuals or cash-oriented businesses, have a much
          higher audit rate

Comprehensive Volume                                                C26 - 3
          Tax Administration (slide 3 of 3)
    • To enhance its enforcement efforts, the IRS has
      focused much effort on:
        – Developing requirements for information reporting and
          document matching
        – Increasing pressure on tax advisers
    • The IRS has recently undertaken a major
      reorganization and adopted new operational
      strategies aimed at improving its efficiency while
      enhancing its interaction with taxpayers

Comprehensive Volume                                              C26 - 4
     Organizational Structure of the IRS

Comprehensive Volume                       C26 - 5
               Letter Rulings (slide 1 of 3)
    • When a tax issue is controversial or involves
      significant tax dollars, a taxpayer may request a
      letter ruling from the IRS
        – The ruling provides a written statement of the position
          of the IRS concerning the tax consequences of a course
          of action contemplated by the taxpayer

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               Letter Rulings (slide 2 of 3)
    • The ruling can only be relied upon by the party
      requesting the ruling
        – Other taxpayers may use the ruling as an indication of
          the IRS’ position on the matter
    • Letter rulings are generally followed by the IRS
      for the taxpayer who requested the ruling as long
      as all material facts of the transaction were
      accurately disclosed in the ruling request

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               Letter Rulings (slide 3 of 3)
    • Letter rulings may be declared obsolete by the IRS
      for other taxpayers
    • A fee is charged by the IRS for processing a ruling

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             Determination Letters
    • Provide guidance regarding a completed
      transaction when the issue involved is
      covered by judicial or statutory authority,
      regulations, or rulings
        – Issued for various death, gift, income, excise,
          and employment tax matters

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     Technical Advice Memorandum
    • Issued by the National Office to IRS personnel in
      response to a request by an agent, Appellate
      Conferee, or IRS executive
        – May be requested by taxpayer when an issue in dispute
          is not treated by the law or precedent and/or published
          rulings or regulations
        – Also appropriate when there is reason to believe that
          the IRS is not administering the tax law consistently

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             Technical Expedited
         Advice Memorandum (TEAM)
    • Can be used during an office or field audit
        – Designed to reflect the position of the IRS in a shorter
          time than a TAM otherwise would take
        – This quicker response time is possible because prior to
          submitting the TEAM request
           • The taxpayer and IRS agree to the facts and conduct a
             presubmission conference
           • Technology, including e-mails and faxes, is used to gather
             facts as part of the process
           • The IRS holds an internal strategic planning meeting,
             discussing potential responses to various holdings that could be
             issued as part of the TEAM

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          IRS Administrative Powers
                          (slide 1 of 3)

    • Examination of records
        – The IRS can examine a taxpayer’s records to
          determine the correct tax due
    • Burden of proof
        – If taxpayer meets the record keeping
          requirement and substantiates income and
          deductions properly, the IRS bears the burden
          of proof in establishing a tax deficiency during
Comprehensive Volume                                         C26 - 12
          IRS Administrative Powers
                               (slide 2 of 3)

    • Assessment and demand
        – The IRS can assess a tax deficiency and demand
          payment of a tax
        – The assessment cannot be made until 90 days after a
          “statutory notice of deficiency” is issued to the taxpayer
           • During the “90 day letter” period, taxpayer may file a petition
             with the U.S. Tax court, which prevents the IRS from
             collecting the amount until after the Tax Court case is resolved
           • After assessment the IRS demands payment within 30 days

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          IRS Administrative Powers
                                (slide 3 of 3)

    • IRS collection procedures
        – If the taxpayer does not pay an assessed tax, the IRS
          can place a lien on all property belonging to the
        – The IRS can garnish (attach) wages and salary and
          seize and sell all nonexempt property by any means
           • A taxpayer’s principal residence is exempt from the levy
             process, unless
               – The disputed tax, interest, and penalty exceed $5,000 and
               – A U.S. District Court judge approves of the seizure

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                IRS Audit Selection
                          (slide 1 of 3)

    • The IRS does not disclose its audit selection
    • Utilizes mathematical formulas to select
        – Likely to contain errors and
        – Yield a substantial amount of additional tax

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                IRS Audit Selection
                           (slide 2 of 3)

    • Examples of audit selection
        – Certain taxpayers are more likely to be audited
          such as:
           • Individuals with gross income > $100,000
           • Self-employed individuals with substantial business
             income and deductions
           • Cash businesses where potential for evasion is high

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                IRS Audit Selection
                       (slide 3 of 3)

    • Most audits of individual tax returns are
      started about two years following the date
      the return is filed

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                Types of IRS Audits
                            (slide 1 of 3)

    • Correspondence audits
        – The return is checked for mathematical accuracy or
          clearly erroneous deductions, etc. soon after the return
          is filed
        – In addition, several months after filing, all 1099s and
          W-2s and other matching information is verified
        – If a discrepancy is found in either of these cases, the
          IRS simply sends the taxpayer an explanatory letter and
          a bill or a refund

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                Types of IRS Audits
                          (slide 2 of 3)

    • Office audits
        – These audits are frequently limited in scope,
          and can be conducted in the IRS office
        – The taxpayer is generally asked to substantiate
          the items requested (i.e., present invoices,
          canceled checks, etc.)

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                Types of IRS Audits
                         (slide 3 of 3)

    • Field audits
        – Commonly used for corporate returns and for
          returns of individuals engaged in business or
          professional activities
        – These audits are generally conducted at a
          taxpayer’s home or business

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            Audit Procedures (slide 1 of 4)

    • Prior to or at the initial interview, the IRS must
        – Provide the taxpayer with an explanation of the audit
          process and
        – Describe the taxpayer’s rights under that process
    • IRS representative must suspend the interview if
      the taxpayer clearly states a desire to consult an
      attorney, CPA, or enrolled agent

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            Audit Procedures (slide 2 of 4)
    • The IRS must grant permission to make an
      audio recording of any interview, upon
      advance request
    • On completion of the examination, the IRS
      agent will file a revenue agent’s report
      (RAR) outlining recommended changes to
      the return (if any)

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            Audit Procedures (slide 3 of 4)
    • The RAR is reviewed internally before the IRS
      assesses an additional tax
    • The taxpayer may accept the RAR or appeal
      within the IRS
    • Appeal within the IRS must be accompanied by a
      written protest unless:
        – The amount of tax does not exceed $10,000 for any tax
        – The adjustment resulted from a correspondence or
          office audit
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            Audit Procedures (slide 4 of 4)
    • Settlement with an IRS agent is based solely
      on the merits of the case, given IRS policy
    • Settlement at the IRS appeals level can be
      based on the “hazards of litigation”—e.g.,
      the likelihood that the courts would agree
      with the IRS position

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         Offers in Compromise and
         Closing Agreements (slide 1 of 2)
    • Offers in compromise
        – IRS can negotiate a compromise if taxpayer is
          financially unable to pay the tax
           • May result in IRS accepting less than full amount of
             tax due
           • Final payment of taxes may be allowed through
             installment payments

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         Offers in Compromise and
         Closing Agreements (slide 2 of 2)
    • Closing agreements
        – May be used:
           • When disputed issues carry over to future years
           • To dispose of a dispute involving a specific issue in
             a prior year or a proposed transaction involving
             future years
        – Binding on taxpayer and IRS

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                       Interest (slide 1 of 3)
    • Congress sets interest rates applicable to
      underpayments and overpayments of tax
        – Rate is determined quarterly
        – Based on federal short-term rates
    • For noncorporate taxpayers
        – The interest rate for both over- and underpayments is
          5% for the first quarter of 2009
    • For most corporate taxpayers
        – The rate is 4 % for overpayments and 5% for

Comprehensive Volume                                              C26 - 27
                       Interest (slide 2 of 3)
    • IRS deficiency assessments
        – Interest accrues from unextended due date of
          return until 30 days after taxpayer agrees to the
          deficiency by signing Form 870
        – If amount due is not paid within 30 days
          interest again accrues on the deficiency

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                       Interest (slide 3 of 3)
    • Refund of taxpayer’s overpayments
        – If refunded within 45 days after return is filed
          or is due, no interest is allowed
        – If taxpayer files an amended return or a claim
          for a refund of a prior year’s tax, interest is
          accrued from the original due date of the return
           • Even then, no interest accrues until a return is filed
             or, if the return has been filed, if the IRS pays the
             refund within 45 days

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          Taxpayer Penalties (slide 1 of 11)
    • A comprehensive array of penalties are used
      to promote compliance with the tax law
    • Failure to file a tax return
        – Penalty is 5% per month (up to 25%) on
          amount of tax due
           • Minimum penalty is $135
        – If failure is due to fraud, rate is 15% per month
          (up to 75%)

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          Taxpayer Penalties (slide 2 of 11)
    • Failure to pay tax due
        – Penalty is 1/2% per month (up to 25%) on amount of
          tax due
        – If failure is after notice of deficiency is received, rate is
          1% per month
    • Both above penalties can be eliminated if
      “reasonable cause” exists for failure to file or pay
        – Failure to file penalty is reduced by any failure to pay
          penalty for the same month

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          Taxpayer Penalties (slide 3 of 11)
    • Accuracy-related penalties
        – 20% of portion of tax underpayment due to:
           •   Negligence or intentional disregard of law
           •   Substantial understatement of tax liability
           •   Substantial valuation overstatement
           •   Substantial valuation understatement
        – Penalty applies only if taxpayer fails to show a
          “reasonable” basis for the position taken on the
          tax return

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          Taxpayer Penalties (slide 4 of 11)
    • For purposes of this accuracy-related
        – Negligence includes any failure to make a reasonable
          attempt to comply with the tax law
           • Penalty also applies to any disregard of rules and regulations
             whether careless, reckless, or intentional
           • Penalty applies to all taxes except when fraud is involved
    • Penalty can be avoided upon showing “reasonable

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          Taxpayer Penalties (slide 5 of 11)
    • Substantial understatement of tax liability
        – Occurs when tax understatement exceeds the larger of
          10% of amount due or $5,000
        – For a C corporation, a substantial understatement
          occurs when tax understatement exceeds the lesser of
           • 10% of the tax due, but at least $10,000
           • $10 million
    • This penalty applies unless:
           • The taxpayer has “substantial authority” for the tax treatment
           • Relevant facts are disclosed in the tax return

Comprehensive Volume                                                          C26 - 34
          Taxpayer Penalties (slide 6 of 11)
    • Penalty for overvaluation of an asset
        – Penalty is 20% of additional tax that would have been
          due if correct valuation had been used
        – Penalty applies if valuation is 150% or more of correct
           • Penalty is doubled if the valuation is overstated by 200% or
        – Penalty applies only to extent that resulting tax
          underpayment exceeds $5,000 ($10,000 for C

Comprehensive Volume                                                        C26 - 35
          Taxpayer Penalties (slide 7 of 11)
    • Penalty for undervaluation of an asset
        – Penalty is 20% of additional tax that would have been
          due if correct valuation had been used
        – Penalty applies if the valuation is 65% or less than the
          correct amount
           • Penalty is doubled if the reported valuation was 40% or less
             than the correct determination
        – The penalty applies only to an additional transfer tax
          liability in excess of $5,000

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          Taxpayer Penalties (slide 8 of 11)
    • Appraiser’s Penalty
        – When a valuation penalty arises due to reliance on an
          appraisal and the appraiser knew the appraisal would be
          used as part of a tax or refund computation, then the
          appraiser pays a penalty equal to the lesser of:
           • 10% of the tax understatement, but at least $1,000, or
           • 125% of the gross income received by the appraiser from the
             engagement (e.g., the appraisal fee collected)

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          Taxpayer Penalties (slide 9 of 11
    • Penalty for Improper Refund Claim
        – If a refund claim is filed and later found to exceed the
          final amount allowed by the IRS or a court, a penalty of
          20% of the disallowed refund results
           • The penalty is waived if the taxpayer can show a “reasonable
             basis” for the refund claim (i.e., probably a 20% chance that a
             court would allow the refund)
           • This penalty is meant to discourage the taxpayer from
             overstating the amount of the refund requested from the IRS

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         Taxpayer Penalties (slide 10 of 11)
    • Civil fraud penalty
        – 75% penalty on any underpayment resulting
          from fraud by the taxpayer
        – For this penalty, burden of proving taxpayer
          civil fraud “by a preponderance of evidence” is
          on the IRS

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         Taxpayer Penalties (slide 11 of 11)
    • Criminal penalties
        – Various monetary fines and/or imprisonment
          may be assessed
        – Burden of proof is on IRS to show guilt
          “beyond the shadow of any reasonable doubt”

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                       Estimated Taxes
                              (slide 1 of 3)

    • A penalty is imposed for failure to pay estimated
        – Applies to individuals, corporations, trusts, and certain
        – Penalty is not imposed if tax due < $500 for
          corporations, $1,000 for all others
    • Quarterly estimated tax payments should be paid
      on 15th day of the 4th , 6th , and 9th months of the
      current year and the 1st month of the following
        – Corporations must make the last quarterly payment by
          the 12th month of the current year
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                       Estimated Taxes
                                (slide 2 of 3)

    • An individual’s underpayment of estimated tax is
      the difference between the estimates that were
      paid and the lesser of :
        – 90% of the current-year tax,
        – 90% of the tax on an annualized income basis, and
        – 100% of the prior-year tax
           • If prior-year AGI > $150,000, the required payment for the
             prior-year alternative is 110 %
           • For 2009, 100% requirement is reduced to 90% if > half of
             year’s gross income came from a small business (fewer than
             500 employees and AGI < $500,000)

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                       Estimated Taxes
                                   (slide 3 of 3)

    • A corp.’s underpayment of estimated tax is the difference
      between the estimates paid and the lesser of:
        – The current-year tax,
        – The prior-year tax, and
        – The tax on an annualized income computation
    • For the prior-year alternative
        – The prior tax year must have been a full 12 months, and
        – A nonzero tax amount must have been generated for that year
        – For large corporations (taxable income of $1 million or more in
          any of the 3 immediately preceding tax years)
            • Can use this alternative only for the 1st installment

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              Other Penalties (slide 1 of 3)
    • False Information with Respect to Withholding
        – A civil penalty of $500 applies when a taxpayer claims
          withholding allowances based on false information
        – A criminal penalty for willfully failing to supply
          information or supplying false or fraudulent
          information is an additional fine of up to $1,000 and/or
          up to one year of imprisonment

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              Other Penalties (slide 2 of 3)
    • Failure to Make Deposits of Taxes and
      Overstatements of Deposits
        – A penalty of up to 15% applies for failure to pay the
          FICA and income tax amounts withheld from wages of
        – A 100% penalty applies if the employer’s actions are
        – In addition, the employer remains liable for the
          employees’ income and payroll taxes that should have
          been paid

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              Other Penalties (slide 3 of 3)
    • Failure to Provide Information Regarding Tax
        – A tax shelter organizer must register the shelter with the
          IRS before any sales are made to investors
           • A penalty of up to $10,000 is assessed if the required
             information is not filed with the Service
        – The shelter organizer must also maintain a list of
          identifying information of all its investors
           • Failure to fully and truthfully maintain the list can result in a
             penalty of up to $100,000 per investment

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       Statutes of Limitations (slide 1 of 2)
    • In general, any tax imposed must be
      assessed within 3 years of filing the return
      (or, if later, the due date of the return)
        – Exceptions to the 3 year rule include:
           • If no return is filed or a fraudulent return is filed,
             there is no statute of limitations
           • If taxpayer omits gross income > 25% of gross
             income stated on the return, statute of limitations is
             extended to six years

Comprehensive Volume                                                  C26 - 47
       Statutes of Limitations (slide 2 of 2)
    • Refund claims
        – Must be filed within 3 years of filing the tax
          return or within 2 years following payment of
          the tax, if later
        – A 7 year period applies to refund claims
          relating to bad debts and worthless securities

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                 Circular 230 (slide 1 of 4)
    • Generally, practice before the IRS is limited to
      CPAs, attorneys, and enrolled agents
        – In limited situations, other parties may be allowed to
          practice before the IRS
           • A taxpayer may always represent himself or herself
           • Employees may represent their employers
           • Corporations may be represented by their officers
           • Partnerships may be represented by any of the partners
           • Trusts, receiverships, guardianships, or estates may be
             represented by their trustees, receivers, guardians, or
             administrators or executors
           • A taxpayer may be represented by whoever prepared the return
             for the year in question

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                Circular 230 (slide 2 of 4)

    • Circular 230 prescribes rules governing
      practice before the IRS
        – Includes prohibitions against:
           • Taking a position on a tax return unless there is a
             realistic possibility of it being sustained
           • Taking frivolous tax return positions

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                Circular 230 (slide 3 of 4)
        – Also contains requirements to:
           • Disclose nonfrivolous tax return positions that fail
             the realistic possibility standard
           • Inform clients of penalties likely to apply and ways
             they can be avoided
           • Make known to clients any error or omission the
             client may have made
           • Submit records lawfully requested by the IRS

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                Circular 230 (slide 4 of 4)
        – Also contains requirements to: (cont’d)
           • Exercise due diligence in preparing and filing tax
             returns accurately
           • Not unreasonably delay disposition of matters
             before the IRS
           • Not charge an “unconscionable fee” for representing
             a client before the IRS
           • Not represent clients with conflicting interests

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            Preparer Penalties (slide 1 of 4)
    •  The Code provides penalties to discourage improper
       actions by tax practitioners
    1. A penalty for understatements due to taking an
       unreasonable position on a tax return
        –   The penalty is imposed if the tax position:
            •   Is not disclosed on the return and there was no substantial authority
                (i.e., a greater than 40% chance) that the tax position would be
                sustained by its merits on a final court review, or
            •   Is disclosed on the return and there was not a reasonable basis (i.e.,
                probably a 20% chance) for the position
        – The penalty is computed as the greater of
            •   $1,000 or
            •   One-half of the income of the practitioner that is attributable to the

Comprehensive Volume                                                                     C26 - 53
           Preparer Penalties (slide 2 of 4)
    2. A penalty for willful and reckless conduct
        – The penalty applies if any part of the understatement of
          a taxpayer’s liability on a return or claim for refund is
          due to:
           • The preparer’s willful attempt to understate the taxpayer’s tax
             liability in any manner
           • Any reckless or intentional disregard of IRS rules or
             regulations by the preparer
        – The penalty is computed as the greater of
           • $5,000 or
           • One-half of the income of the practitioner that is attributable to
             the return or claim

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           Preparer Penalties (slide 3 of 4)
    3. A $1,000 penalty ($10,000 for corps.) is imposed
       against persons who aid in preparation of returns
       they know (or have reason to believe) would result
       in an understatement of tax liability of another
        – If this penalty applies, neither the unreasonable position
          penalty (item 1) nor the willful and reckless conduct
          penalty (item 2) is assessed

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           Preparer Penalties (slide 4 of 4)
    4. A $50 penalty is assessed against the preparer for
       failure to sign a return or furnish the preparer’s
       identifying number
    5. A $50 penalty is assessed if the preparer fails to
       furnish a copy of the return or claim for refund to
       the taxpayer
    6. A $500 penalty may be assessed if a preparer
       endorses or otherwise negotiates a check for
       refund of tax issued to the taxpayer

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         Privileged Communications
    • Communications between attorney and client are
      protected from disclosure to other parties (such as
      the IRS and the tax courts)
        – Similar privilege of confidentiality extends to tax
          advice between a taxpayer and tax practitioner
        – Not available for matters involving:
           • Criminal charges
           • Questions brought by other agencies, such as the Securities and
             Exchange Commission
           • Promoting or participating in tax shelters

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               AICPA Standards For
               Tax Services (slide 1 of 6)
    Statement No. 1: Tax Return Positions
        – Under certain circumstances, a CPA may take a
          position that is contrary to that taken by the IRS
           • Must have a good faith belief that the position has a realistic
             possibility (i.e., probably a one-in-three chance) of being
           • Fully advise client of the risks involved and the associated
        – The CPA should not take a questionable position based
          on the probabilities that the client’s return will not be
          chosen by the IRS for audit

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              AICPA Standards For
              Tax Services (slide 2 of 6)
    Statement No. 2: Questions on Returns
        – A CPA should make a reasonable effort to
          obtain from the client, and provide, appropriate
          answers to all questions on a tax return before
          signing as preparer
           • Reasonable grounds may exist for omitting an

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              AICPA Standards For
              Tax Services (slide 3 of 6)
    Statement No. 3:Procedural Aspects of
      Preparing Returns
        – In preparing a return, a CPA may in good faith
          rely without verification on information
          furnished by the client or by third parties
           • The CPA should make reasonable inquiries if the
             information appears to be incorrect, incomplete, or
           • The CPA should refer to the client’s returns for prior
             years whenever appropriate

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              AICPA Standards For
              Tax Services (slide 4 of 6)
    Statement No. 4:Estimates
        – A CPA may prepare a tax return using
          estimates received from a taxpayer if it is
          impracticable to obtain exact data
           • The estimates must be reasonable under the facts
             and circumstances as known to the CPA
           • When estimates are used, they should be presented
             in such a manner as to avoid the implication of
             greater accuracy than exists

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              AICPA Standards For
              Tax Services (slide 5 of 6)
    Statement No. 5: Recognition of
      Administrative Proceeding or Court
        – As facts may vary from year to year, so may the
          position taken by a CPA
        – In these types of situations, the CPA is not
          bound by an administrative or judicial
          proceeding involving a prior year

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              AICPA Standards For
              Tax Services (slide 6 of 6)
    Statement No. 6: Knowledge of Error
        – A CPA should promptly advise a client upon
          learning of an error in a previously filed return
          or upon learning of a client’s failure to file a
          required return
           • The error or other omission should not be disclosed
             to the IRS without the client’s consent
           • If the past error is material and is not corrected by
             the client, the CPA may be unable to prepare the
             current year’s tax return

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       If you have any comments or suggestions concerning this
       PowerPoint Presentation for South-Western Federal
       Taxation, please contact:

                       Dr. Donald R. Trippeer, CPA
                               SUNY Oneonta

Comprehensive Volume                                             C26 - 64

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