Free IRS Enrolled Agent SEE Part 3 (Representation, Practices and Procedures) Representation Before the IRS Practice Questions
Representation Before the IRS covers Power of Attorney via Form 2848, Tax Information Authorization via Form 8821, the CAF (Centralized Authorization File) processing, building the taxpayer’s case, financial-situation analysis using Form 433-A / B / F, supporting documentation requirements, and identifying applicable IRC and Treasury Reg authority.
Sample Questions
Question 1
Easy
Form 433-F is used by the IRS to...
Solution
Form 433-F, Collection Information Statement, is a streamlined version of the 433-A used primarily by the Automated Collection System and certain Revenue Officers to gather a taxpayer's income, expense, asset, and liability information when establishing an installment agreement, evaluating CNC status, or otherwise determining ability to pay (IRM 5.15.1; Pub 594).
Question 2
Medium
Under the Golsen rule, the U.S. Tax Court will:
Solution
Golsen v. Commissioner, 54 T.C. 742 (1970), aff'd, 445 F.2d 985 (10th Cir. 1971), holds that the Tax Court will follow a directly on-point decision of the Court of Appeals to which the case is appealable, even if the Tax Court itself disagrees, in order to avoid an inevitable reversal.
Question 3
Hard
A typical 'saving clause' in a U.S. bilateral income tax treaty operates to:
Solution
The saving clause, found in essentially every U.S. income tax treaty (including the U.S. Model), permits the United States to tax its citizens and lawful permanent residents as though the treaty did not exist. A separate paragraph then carves out specifically enumerated exceptions (typically including provisions on government pensions, child support, social security agreements, and certain procedural rights) to which the saving clause does not apply.