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Thomas Chen is a resident of Connecticut. In his hometown of Glastonbury, Chen opened a coffee shop along Main Street where he specializes in serving and roasting coffee from the northern region of Columbia. While Chen’s coffee shop has been quite lucrative, he was recently audited by the IRS. During the audit, the IRS challenged several items on Schedule C of his timely-filed Form 1040 for taxable year 2020. Chen filed his return for taxable year 2020 on April 11, 2021, and the audit commenced on February 1, 2022. The revenue agent issued an RAR on October 5, 2021, and a statutory notice of deficiency on December 22, 2021. If Chen wants to legally challenge the deficiency asserted by the IRS, he can file a claim in the:

IRS Agent Stella May works in the SB/SE division in New Carrollton, MD. Stella has been working a case involving Will Smith. During lunch one day, Stella begins talking with her colleagues Zio and Lucy about the fact that Will Smith improperly took a deduction on his tax return and made over $8 million last year. Are Stella’s communications with her colleagues Zio and Lucy permissible? 

10. What must occur before the Notice of Federal Tax Lien is filed?

Which of the following is not a requirement for written advice under Circular 230, § 10.37?

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?