9. Christina and her husband Paul both live in Portland, ME and own a cookie baking business. For the latest taxable year, Christina and Paul filed their federal income tax returns jointly and reported a tax due of $4,000. Two years later, the IRS opened an audit of Christian and Paul’s return and asserted that $2,000 remains due to the IRS. In addition to the $2,000, the IRS assessed penalties and interest in the amount of $750 and $250, respectively. What is the deficiency?

The Atlanta field office of the Internal Revenue Service conducted an office examination of Shoumik Akar’s 2021 federal income tax return. Akar, a Marietta, GA native, mailed his Form 1040 using the U.S. Postal Service’s Certified Mail service on April 14, 2022. Akar’s return was not, however, received by the IRS until April 17, 2022. On January 9, 2023, the Atlanta field office began their examination of Akar’s return. The examination was lengthy on account of a multitude of document requests, which slowed the examination by approximately 6 months. Akar eventually requested an Appeals Conference during the examination, but was unable to come to a resolution concluding the Audit. On December 31, 2023, the IRS concluded its audit and mailed a Notice of Deficiency to Akar’s last known address. Akar was in the United States when the notice of deficiency was issued to him, but he failed to file a petition. When does the ASED expire? (Note: when inserting your answer, ensure that it is in the following format: “01/01/2020” otherwise it will automatically be marked incorrect.

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

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?

4. Which of the following is not required to be included within a statutory notice of deficiency in order for it to be 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? 

6. Pursuant to the U.S. Constitution, tax legislation generally must be initiated in the U.S. Senate, sent to the Senate Finance Committee, and then be sent for consideration to the House Ways & Means Committee?

5. Daniel Fisk is an attorney who practices estate and tax law in Washington, D.C. and Maryland. Fisk primarily handles drafting wills and trusts for his clients, but occasionally prepares individual income tax returns and sends documents to the IRS in support of clients who are being audited. In Attorney Fisk’s communications and filings with the IRS, he does not include his PTIN. Do Attorney Fisk’s activities constitute practice before the IRS?  

7. Tim Rasmus is an individual taxpayer who works in finance at BCM Investments, Inc. As part of Tim’s role as an analyst, he frequently interacts with tax law and has become motivated to file his own tax returns. Tim would like to take a particular position on his tax return that he is unsure how the IRS will handle. If Tim is seeking to find an Announcement to obtain more information on the issue he is dealing with, where should he look? 

3. Jacob Wrentham, a 31-year-old single filer, has been notified by the IRS that his return is being audited. According to documentation he has received in the mail, the audit is focused solely on Jacob’s timely-filed Form 1040, Line 12. The audit of Jacob’s return is most likely a: