In the first paragraph explain Revenue Procedure 2017-33 in two or three sentences. Provide a proper citation. In your final sentence or two explain its current significance, especially for a Hawaii client's 2018 tax return having similar facts, but with a restaurant business.

In the second paragraph, explain the Tax Court's 2017 decision for Jeremy Jacobs. Provide a proper citation. In your final sentence or two explain its current significance, especially for a Hawaii client's 2018 tax return having similar facts, but with a restaurant business.

In the first paragraph discuss the penalties in Section 6694. Make sure you address: when the penalty applies, when the taxpayer's position is unreasonable, and when the penalty isnotimposed. Do NOT discuss how the penalty is calculated.

In the second paragraph, assume you work for the IRS. Apply the law to the following facts, citing any relevant authority: Ben is a tax return preparer. He failed to find and have the client Carla follow the relevant treasury regulations for depreciation, leading to a $60,000 understatement on Carla's tax return. Ben did not sign Carla's tax return. Carla paid Ben's company $5,000 for his tax preparation services. Ben was employed by TaxPros LLC. Make sure you address who (if anyone) any penalty under sec. 6694 applies to, citing the relevant precise authority. Calculate the penalty, if any.