Self-determination of Tax
IRS Guidance
Reporting and Paying Tax
Limitations Periods
Refund Litigation
100
Law that says that revenue legislation starts at the House of Representatives
What is Article 1 of the Constitution
100
The highest form of guidance
What is treasury regulation
100
Government branch that determines the tax rate
What is Congress
100
Requirement the courts only look at the grounds raised in the refund claim presented to the IRS
What is the variance doctrine
100
Form the taxpayer can consent to allow the IRS more time to assess their tax
What is Form 872
200
4 interpretive methods of reading a state
What is realism, purposivism, intentionalism, and textualism
200
The two broad categories of tax administrative guidance.
What is informal public guidance and private guidance
200
The Code section that requires tax payers to file a tax return
What is section 6011
200
The Code section that gives the IRS 3 years to assess a tax from the the date the return is filed
What is section 6501
200
Action taxpayer may request if the IRS assesses during the restricted period after the issuance of a notice of deficiency
What is abatement of assessments
300
The case holding that the IRS has a duty of consistency in its treatment of taxpayers in private letter rulings.
What is IBM
300
Case holding that courts defer to the IRS where Congress has delegated its lawmaking authority to the IRS
What is Chevron
300
The manner of obtaining an extension for paying tax.
What is apply in advance, must have good reason, must show undue hardship
300
Requirements for IRS to grant extension to pay
What is apply in advance, must have good reason, must show undue hardship
300
Amount of refund that can be claimed when taxpayer filed for a $7,000 refund on November 2, 1997, after the tax payer received an extension and paid $15,000 in taxes by the due date in 1994. The tax payer made no payments after this payment.
What is zero dollars
400
Group that works out the language of a bill between the two chambers and drafts a report
What is conference committee
400
Judge who wrote/said the following quote: "Tax payers are entitled to many choices that will provide tax benefits.
What is Judge Learned Hand
400
The form for making a refund claim.
An amended return.
400
The Code section that provides that withholding taxes are deemed paid on the due date of the return
What is ยง6513
400
The date the payment is deemed paid when the taxpayer received a six month extension and paid the taxes on June 6
What is June 6
500
Method of looking at the intent of a reasonable Congress
What is the purposivism method
500
Guidance that is published against the wishes of the IRS
What is "private" guidance.
500
The requirements for a valid return.
What is 1. Sufficient data to calculate the tax liability 2. The document must purport to be a return 3. An honest and reasonable attempt to satisfy the requirements of tax law 4. Document must be signed under penalties of perjury
500
Case holding that absent any provision deeming a remittance a payment, a remittance made before any tax liability is due and owing is considered a deposit that does not begin the statute of limitations on a refund claim because it is not a payment of tax.
What is Rosenman
500
The amount of time the taxpayer has to file for a refund
What is three years from the filing date if the tax return was filed, or two years from the date the tax was paid
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