A) The burden of proof is on the taxpayer to establish that no fraud was committed.
B) Fraudulent behavior is more than mere negligence on the part of the taxpayer.
C) The penalty is 100% of the underpayment.
D) Fraud is defined in Code §§ 6663b) and f) .
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True/False
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Multiple Choice
A) $10,000.
B) $9,000.
C) $1,000 minimum amount) .
D) $0.
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Multiple Choice
A) The penalty rate is 20%.
B) The penalty applies whenever the taxpayer takes a return position that is contrary to a court decision.
C) The penalty applies when the taxpayer does not keep records adequate to compute the tax correctly.
D) The penalty is waived if the taxpayer uses Form 8275 to disclose a return position that is reasonable but contrary to the IRS position.
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True/False
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Essay
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Multiple Choice
A) The taxpayer but not the IRS) can appeal a contrary judgment.
B) The IRS but not the taxpayer) can appeal a contrary judgment.
C) Either the IRS or the taxpayer can appeal a contrary judgment.
D) Neither the IRS nor the taxpayer can appeal a contrary judgment.
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Multiple Choice
A) Treasury Secretary.
B) National Taxpayer Advocate.
C) Director of the Whistleblower Office.
D) Chief Appeals Officer.
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Essay
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True/False
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Multiple Choice
A) No return at all is filed.
B) An investment in a marketable security is worthless.
C) A taxpayer discovers an inadvertent overstatement of deductions equal to 30% of gross income.
D) A taxpayer inadvertently omits an amount of gross income equal to 30% of the gross income stated on the return.
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True/False
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