A) Fraudulent behavior is more than mere negligence on the part of the taxpayer.
B) The burden of proof to establish the penalty is on the government.
C) The penalty is 100% of the underpayment.
D) Fraud is defined in Code ยงยง 6663(b) and (f) .
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Multiple Choice
A) IRS.
B) AICPA.
C) ABA.
D) SEC.
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Multiple Choice
A) $0.
B) $7,000.
C) $10,000 (maximum penalty) .
D) $14,000.
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Multiple Choice
A) Is waived if the taxpayer also was charged with his/her own valuation penalty.
B) Applies if the appraiser knew that the appraisal would be used in preparing a Federal income tax return.
C) Equals 10% of the appraised value of the property,with a $5,000 minimum penalty.
D) Can be as much as 200% of the appraisal fee that was charged.
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Multiple Choice
A) The taxpayer has substantial authority for the treatment taken on the tax return.
B) The relevant facts affecting the treatment are adequately disclosed in the return or on Form 8275.
C) The IRS failed to meet its burden of proof in showing the taxpayer's error.
D) All of the above statements are correct.
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True/False
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True/False
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Multiple Choice
A) The tax reduction attributable to the disputed deduction did not exceed $5,000.
B) There was a reasonable basis for Joan's interpretation of the travel deduction rules.
C) There was substantial authority for Joan's interpretation of the travel deduction rules.
D) The IRS found that the travel deduction was frivolous,but Joan disclosed the position in an attachment to the return.
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True/False
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True/False
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