Practice & Procedure Pop Quiz #2
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A and B, whose lakeshore vacation homes adjoin one another and suffer a significant loss of lake frontage in a storm.  A and B are not related TPs.  Each received a notice of deficiency disallowing the casualty loss. May they file a joint petition?   *
1 point
TP files a petition and says he was unsettled by his recent divorce and unable to pay his taxes.  The petition has no other allegations of error by the IRS.  The IRS files a motion to dismiss for failure to state a claim upon which relief can be granted.  Should the TC rule in favor of the IRS? *
1 point
What is the effect if a TC petition is silent on one or more issues raised in the NOD? *
1 point
Prior to TC trial the IRS requests admissions from the TP.  TP cannot recall the information requested.  May TP respond by asserting a lack of knowledge? Check all that apply *
1 point
Required
After TP has filed a petition, how long does IRS have to file an answer? *
1 point
After IRS files an answer how many days does TP have to file a reply?   *
1 point
How many days before calendar call must formal discovery end? *
1 point
How can TP assure a petition will be deemed timely filed if TP cannot physically deliver the petition to the Court and if the last date for timely filing is imminent?  Check all that apply: *
1 point
Required
The IRS issues a NOD to X Corporation – it failed to pay state franchise taxes and its corporate charter was forfeited.  May X Corp maintain a TC proceeding? *
1 point
TP is convicted of §7201 willful attempt to evade or defeat tax.  Is TP collaterally estopped from challenging a §6663 penalty? *
1 point
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