1.A taxpayer only has the right to appear in Tax Court if the taxpayer files a petition within 90 days of the IRS issuing the taxpayer a Notice of Deficiency. Therefore, partnerships cannot bring cases in Tax Court because partnerships are income tax pass-through entities and there is no tax due at the partnership level. Thus, no tax due, no deficiency, no Notice of Deficiency.

a. True.

b. False.

2.Your client is audited, and it is revealed that his/her Form 1040 does not match the related Form 1065. You client received a Schedule K-1 from the partnership indicating that a certain amount was income earned by the partnership and allocated to your client. However, your client did not report that amount as income. The client did not disclose the mismatch to the IRS. What can the IRS do?

a. Nothing yet. First, the IRS has to send a notice proposing a possible tax assessment against your client, the partner.

b. Skip the normal deficiency procedures and assess a tax against your client immediately.

c. First, the IRS has to send a notice to the partnership indicating that there is a mismatch.

d. Whatever it wants.