IRS Practice and Procedure

In each of the following cases, state whether Appeals has jurisdiction over the issue:

a. Bill files his return late, paying the tax due plus interest. The IRS sends Bill a notice assessing a failure-to-file penalty. Bill believes that the penalty should not be assessed, because he has a reasonable cause for not filing.

b. Hank files an amended return requesting a refund of tax. The refund request is rejected by the IRS.

c. Don owes the IRS a sizeable sum that he cannot pay. He submits an offer in compromise, proposing to pay one-half of the liability if the IRS forgives the other half. The IRS collection officer assigned to the case rejects the offer.