2018 September/October EA Journal Exam
IRS Program Number: X9QQU-T-00530-18-S
I Spy Tax Fraud! Do You?
By Alan L. Pinck, EA, & Ann E. Kummer, EA, CPA
This article discusses what EAs should do if they find themselves representing clients who have engaged in fraudulent activity. The article discusses Parts 9 (Criminal Fraud) and 25.1 (Civil Fraud) of the Internal Revenue Manual. Other topics include the badges of fraud, case studies, and preparer due diligence.
The IRS Revenue Officer: Friend or Foe?
By Howard S. Levy, JD
This article presents five strategies an enrolled agent should use when working with revenue officers in a collections case. Topics include collection due process appeals, meeting deadlines, and keeping clients in compliance.
Overview of Practice before the U.S. Tax Court
By Sherrill Trovato, EA, USTCP
This article focuses on income tax deficiency and collection due process jurisdiction as it relates to the U.S. Tax Court. Topics include court basics, IRC §7502, lien and levy actions, and more.
Is an Analysis of the Thought Process of the Approving Supervisor Required in a Case Involving a Trust Fund Recovery Penalty?
By Steven R. Diamond, CPA
Under IRC §§6320 and 6330, taxpayers have the right to a collection due process hearing which provides them with an independent review by the IRS Office of Appeals of the decision to file a Notice of Federal Tax Lien or IRS’s proposal to undertake a levy action. At the hearing, the taxpayer has a statutory right to raise any relevant issues related to the unpaid tax, lien, or proposed levy, including the appropriateness of the collection action. This article summarizes 150 T.C. No. 9.