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111. In 1997, the IRS sued Taxpayer Q in federal district court and obtained a judgment against Q for unpaid taxes, penalties and interest. The

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111. In 1997, the IRS sued Taxpayer Q in federal district court and obtained a judgment against Q for unpaid taxes, penalties and interest. The IRS took all the appropriate post-judgment actions required by law. However, shortly thereafter, the file fell behind the attorney's desk and was not discovered until recently. The IRS is now seeking to collect the judgment against Q. Q is defending this collection effort by asserting that there is a 10 year limitations period for collection of assessed taxes and that this 10 year period has long ago expired. Q will prevail on this theory. a. True b. False 112. The IRS can assess civil penalties for a taxpayer's failure to file a return or for a taxpayer's failure to pay the tax but not for both. a. True b. False 113. The IRS is entitled to assess and collect an accuracy related penalty even if the taxpayer has substantial authority for a tax position that is contrary to the position of the IRS, even if the taxpayer discloses the taxpayer's contrary position to the IRS on the appropriate disclosure form and even if the taxpayer has a very high probability of success with that contrary position in litigation. a. True b. False 114. Taxpayers (other than taxpayers for whom adequate payroll tax withholdings are made) are required to pay quarterly deposits toward their tax liability. a. True b. False 115. Company X was having a cash flow shortage during early 2020. Faced with a choice between paying the company's rent for April, 2020 and making its April deposit for payroll taxes, the CFO opted to pay the rent instead of the taxes. Company X but not the CFO, in his individual capacity, can be held liable for both the payroll taxes and for failure to deposit penalties. a. True b. False

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