122 Wiley Lawyer has organized and promoted a series of tax shelters which the IRS believes are abusive. Wiley asserts that the IRS can assess a penalty against him for organizing and promoting an abusive tax shelter but, other than assessing the penalty against him, that the IRS has no other legal remedies that it can utilize to stop him from continuing his abusive tax shelter operation. The IRS nevertheless bring a lawsuit against Wiley to enjoin him from this action. Based on Wiley's assertion, the IRS has no legal authority to do anything to Wiley other than continue to assess penalties against him. a. True b. False 121. If a taxpayer fails to pay their tax by the due date for that tax, the IRS can assess an array of civil penalties or it can charge interest on the unpaid tax but it cannot do both. a. True b. False 107. The periods for assessments of taxes and for collections of taxes are set by statute and cannot be extended by a taxpayer agreement. a. True b. False 108. The client confidentiality privilege rules for non-attorney authorized tax practitioners are exactly the same as those rules for attorney tax practitioners. a. True b. False