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True or False: The Final Partnership Adjustment is the final step concluding an audit of a BBA partnership? 

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?

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? 

10. An individual is not considered to be practicing before the IRS, unless and until, they have a valid Form 2848 or Form 8821 on file with the IRS? 

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?

9. An excerpt from I.R.C. § 6702 of the Internal Revenue Code provides as follows:  IRC § 6702 (b) Civil Penalty for Specified Frivolous Submissions.  (1) Imposition of Penalty. Except as provided in paragraph (3), any person who submits a specified frivolous submission shall pay a penalty of $5,000. (2) Specified Frivolous Submission. For purposes of this section – (A) Specified frivolous submission. The term “specified frivolous submission” means a specified submission if any portion of such submission— (i) is based on a position which the Secretary has identified as frivolous under subsection (c), or (ii) reflects a desire or delay to impede the administration of Federal tax laws. (B) Specified submission. The term “specified submission” means— (i) a request for a hearing under – (I) section 6320 (relating to notice and opportunity for hearing upon filing of notice of lien) or  (II) section 6330 (relating to notice and opportunity for hearing before levy) Which of the following statements from the statute above is a sub clause?

12. Assume the same facts as Question #9. Which of the following statements from the statute above is a subsection?

1. On September 12, 2010, the IRS issued PLR 2010005369, which addresses a related-party transaction involving bonds. A few years after the PLR was published, the IRS issued regulations that adopted the ruling contained within the PLR. Promethius Corporation, a sophisticated taxpayer with a tax issue similar to the scenario addressed in PLR 20100005369, wishes to cite to it as authority in its discussion with IRS agents. What should Promethius Corporation cite to? 

4. On February 10, 2013, the IRS issued Treas. Reg. § 1.385-1T which provided rules pertaining to the analysis of whether an instrument is debt or equity for federal income tax purposes. X Corporation, a sophisticated taxpayer wishes to rely upon the regulation to support its position that a loan it extended to a related party is debt rather than equity. Can it rely upon the regulation for taxable year 2023? 

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