IRS Practice And Procedures Lessons
Lesson 1
The IRS as an Administrative Agency
1. Briefly describe the organization of the IRS and how authority to administer the internal revenue law is delegated to it by Congress and the Secretary of the Treasury.
2. The complaint is frequently heard that the IRS appears to operate as if there were no restrictions upon its authority to investigate and harass taxpayers. Discuss what controls Congress, the courts, and the executive branch exert over the IRS and its administration of the tax law.
3. Describe the two methods available for obtaining judicial review of a proposed deficiency by the IRS.
4. In any judicial proceeding involving proposed assessment of income tax, does the IRS or the taxpayer carry the burden of proof?
5. What is the purpose and function of the Taxpayer Advocate?
6. Who may “practice” before the IRS on behalf of taxpayers?
7. A taxpayer represented by someone authorized to practice before the IRS must file a power-of-attorney form. What is this, how is it filed, and why is it necessary?
8. What is the Centralized Authorization File (CAF)?
9. To whom does the Chief Counsel of the IRS report?
10. You are researching a point of law and discover a private letter ruling that supports your position. May you use this authority in a memorandum of law to the IRS or in a court brief?
11. You have just received a frantic telephone call from a client saying that his bank account has been frozen because of an IRS lien. He wishes to sue the bank and the IRS because they have denied him his property without due process of law as guaranteed by the Constitution. What is you advice?
12. Your client demands that his dispute with the IRS be heard by a jury of his peers, all of whom he is sure will agree with him. May a taxpayer or the government request a trial by jury?
Lesson 2
Taxpayer Access to Information
1. What is the Freedom of Information Act (FOIA), and for what purpose was it enacted? How does FOIA affect taxpayers and tax
The IRS as an Administrative Agency
1. Briefly describe the organization of the IRS and how authority to administer the internal revenue law is delegated to it by Congress and the Secretary of the Treasury.
2. The complaint is frequently heard that the IRS appears to operate as if there were no restrictions upon its authority to investigate and harass taxpayers. Discuss what controls Congress, the courts, and the executive branch exert over the IRS and its administration of the tax law.
3. Describe the two methods available for obtaining judicial review of a proposed deficiency by the IRS.
4. In any judicial proceeding involving proposed assessment of income tax, does the IRS or the taxpayer carry the burden of proof?
5. What is the purpose and function of the Taxpayer Advocate?
6. Who may “practice” before the IRS on behalf of taxpayers?
7. A taxpayer represented by someone authorized to practice before the IRS must file a power-of-attorney form. What is this, how is it filed, and why is it necessary?
8. What is the Centralized Authorization File (CAF)?
9. To whom does the Chief Counsel of the IRS report?
10. You are researching a point of law and discover a private letter ruling that supports your position. May you use this authority in a memorandum of law to the IRS or in a court brief?
11. You have just received a frantic telephone call from a client saying that his bank account has been frozen because of an IRS lien. He wishes to sue the bank and the IRS because they have denied him his property without due process of law as guaranteed by the Constitution. What is you advice?
12. Your client demands that his dispute with the IRS be heard by a jury of his peers, all of whom he is sure will agree with him. May a taxpayer or the government request a trial by jury?
Lesson 2
Taxpayer Access to Information
1. What is the Freedom of Information Act (FOIA), and for what purpose was it enacted? How does FOIA affect taxpayers and tax