A taxpayer timely receives a Final Notice of Intent to Levy and Notice of Your Right to a Hearing. The taxpayer wants an independent review before levy action and wants to preserve the right to seek Tax Court review of the determination. What should the representative generally do?
A. Request an equivalent hearing after the CDP deadline expires
B. Use the Collection Appeals Program instead of requesting CDP review
C. Propose an installment agreement without requesting the offered hearing
D. Timely file Form 12153 by the deadline stated in the notice
Source: PRIMARY -- Publication 1660, sections 'Collection Due Process (CDP) Hearing' and 'How do you request a CDP or equivalent hearing?' (https://www.irs.gov/pub/irs-pdf/p1660.pdf)
A taxpayer wants an enrolled agent to argue the taxpayer's position in an IRS examination and receive confidential tax information for that matter. Which authorization is generally appropriate?
A. Form 8821 naming the agent for the same matters and periods
B. Form 2848 covering the agent, tax matters, and periods
C. A written information request signed only by the enrolled agent
D. Form 56 identifying the enrolled agent as the taxpayer's fiduciary
Source: PRIMARY -- Instructions for Form 2848, sections 'Purpose of Form' and 'Authority Granted' (https://www.irs.gov/instructions/i2848)
An electronic return originator receives an IRS rejection of an individual return because a correctable taxpayer-identification entry does not match IRS records. The filing deadline has not passed and the taxpayer promptly supplies verified corrected information. What should the ERO generally do?
A. Correct and timely retransmit with the taxpayer's authorization
B. Treat the original transmission date as proof that filing is complete
C. Submit the same rejected data again without investigating the mismatch
D. Convert the return to paper without obtaining the taxpayer's approval
Source: PRIMARY -- Publication 1345, section 'Acknowledgements of Transmitted Return Data' and subsection addressing rejected electronic returns (https://www.irs.gov/pub/irs-pdf/p1345.pdf)
A taxpayer executes Form 2848 appointing an enrolled agent for an examination. The taxpayer then asks the agent to sign the taxpayer's income-tax return merely because the taxpayer is traveling. No regulatory exception or specific signature authorization applies. What should the agent conclude?
A. The existing examination appointment also authorizes return signing
B. The agent may not sign the return on these facts without a qualifying regulatory exception
C. The agent may sign after documenting the taxpayer's travel schedule
D. The agent may sign if the taxpayer separately authorizes information disclosure
Source: PRIMARY -- Instructions for Form 2848, section 'Authority Granted' and subsection 'Signing a tax return' (https://www.irs.gov/instructions/i2848)
Two former business partners ask one enrolled agent to represent both of them in an IRS examination. Their positions may become directly adverse, but the agent reasonably believes competent and diligent representation of each remains possible and representation is not prohibited by law. What additional step is required before accepting the conflict?
A. Obtain informed written consent from each affected client
B. Disclose the conflict only to the revenue agent assigned to the examination
C. Obtain oral consent from both clients and document it only if a dispute arises
D. Use separate powers of attorney without addressing the adverse interests
Source: PRIMARY -- 31 CFR 10.29(a)–(b), conflict conditions, informed written consent, retention, and production requirements (https://www.ecfr.gov/current/title-31/subtitle-A/part-10/section-10.29)
