The policy that the IRS will not prosecute taxpayers who admit to tax evasion, assuming the taxpayer meets the requirements.
What is the voluntary disclosure policy?
100
Interpretive method that requires one to look at the original intent.
What is intentionalism?
100
the purpose of an assessment
What is to establish a liability?
100
3 types of audits
What are field audits, office audits, and correspondence audits?
100
number of senior judges on the tax court
What is ten?
200
The 3 elements required for the crime known as tax evasion.
What is a deficiency due and owing, an attempt to evade or defeat tax, and acted willfully (intentionally violated known legal duty)?
200
highest form of IRS guidance
What are treasury regulations?
200
Action IRS cannot take without assessing the tax.
What is collections?
200
method IRS uses to choose which returns to audit
What is the DIF score?
200
opinion where the judge reads the opinion on the record
What is bench opinion?
300
4 parts of the collection process
What are assessment, notice and demand, federal tax lien, NFTL, levy, and sale?
300
IRS rule pertaining to timely filing that will become obsolete because of changes in technology.
What is the mailbox rule?
300
type of assessment that requires approval from the Chief Counsel
What is jeopardy assessment?
300
the power taxpayer's representative must have to represent taxpayer without taxpayer present
What is power of attorney?
300
taxpayer has 90 days to file this after receiving a SNOD
What is a petition?
400
Tax protester who claimed it was a violation of the 5th amendment to impose taxes
Who is Irwin Schiff?
400
statute of limitations for audit consideration
What is three years?
400
3 times when an assessment can take place
What is initial assessment, assessment through appeals, and assessment after tax court?
400
2 Powell factors
What are the investigation is for a legitimate purpose, the inquiry will be relevant to that purpose, the information is not already in the IRS's possession, and the administrative requirements of the code have been followed?
400
latin term for claim preclusion
What is res judicata?
500
3 types of penalties
What failure to file, failure to pay, and civil fraud?
500
3 exceptions to the state of limitations
What is mitigation, equitable recoupment, and interest?
500
4 types of assessments
What is summary, deficiency, jeopardy, and termination?
500
mental impressions, thoughts, and strategies of an attorney
What is opinion work product?
500
3 requirements that must be met to recover litigation costs
What is substantially prevail, administrative exhaustion, and limitations on finances?