Law that says that revenue legislation starts at the House of Representatives
What is Article 1
100
The highest form of guidance
What is treasury regulation
100
Individuals who determine 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
2 forms of mutually exclusive guidance
What is informal public guidance and formal public guidance
200
the section that requires tax payers to file a tax return
What is section 6011
200
what section of the code give the IRS 3 years to assess a tax from the the return is filed
What is section 6501
200
Action IRS may take if it assesses during the restricted period after the issuance of a notice of deficiency
What is abatement of assessments
300
Case whose black letter law is that the IRS is not required to treat taxpayers equally
What is US v. Stichting
300
Case where the law is still valid, but without much teeth
What is National Muffler
300
Judge who wrote/said the following quote: "Tax payers are entitled to many choices that will provide tax benefits.
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
Form a refund claim of tax penalties is made on
What is Form 843
400
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
7 types of private guidance
What is private letter rulings, field service advice, technical advice memoranda, action on decision, internal revenue manual, and general counsel memoranda
500
4 Beard requirements
What is 1. Must be sufficient data to calculate the tax liability 2. The document must purport to be a return 3. There must be an honest and reasonable attempt to satisfy the requirements of tax law 4. TP must execute the return under penalties of perjury
500
case whose rule is 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 if the tax return was filed, then three years, but if not then two years from the tax was paid