Ms. Burke, an unmarried taxpayer, has come to see you about some tax issues that are troubling her and would like some answers.

1. She filed her tax return for year 1 on February 1, year 2. a. She asks, "when will the statute of limitations close on the return?" She assures you that it is not fraudulent and the only debatable issue is a big deduction she took and now wonders about. See 6501 and 6503(a)(1) and 6512(a). b. She also wonders if it is true that the IRS could force her to extend the statute of limitations and if so, what she should do. See 6501(c)(4).

2. Same as point "a above, but she willfully concealed a lot of income from the IRS. See 6501(c) and 6531.

3. Same as point "a above, but she never filed her year 1 return (Form 1040). See 6501(c).

4. Instead of owing money, she forgot a big deduction and thinks she is entitled to a refund. You warn her that she will have to file an amended return[1], the statement of procedural rules 601.105(e)(2) requires the IRS to review the entire return and perhaps bring up new weaknesses in the return, but she says she can live with that. So, she asks, what is the last day she can file for the refund? See 6511(a).

5. Some months have passed and she is in the midst of the audit. The agent has issued her a summons (1) for various documents, some of which are embarrassing and, she thinks, not pertinent to the audit and (2) to give testimony. What can be done to stop this? See 7602(a), (c).

6. You have done such a fine job that Ms. Burke has said good things about you to her volatile cousin, Larry. Recently, Larry was also notified that he was about to be audited about his business expense deductions, and he feels the Revenue Agent is insinuating that he is a liar. He is furious and says, "I am taking this to court, period!" What advice would you give him?

7. Ms. Burke is back. She says the IRS has finished the audit and she has had her Appeals Conference (she engaged someone else behind your back, namely a relative who said he would do it for free, but she thinks he did a sloppy job). The Appeals Conference went badly, and there was complete disagreement. The District Office of the IRS has sent her a 90 day letter (notice of deficiency). It is dated August 1, of this year, but she did not actually get it because she moved and it was sent to her prior address. The IRS did not know she moved and she only got the letter because her former landlord salvaged it from the trash, which he likes to go through. The letter was issued 88 days ago and postmarked as of 87 days ago. a. Can she safely ignore it? See 6212(b). b. If she wants to file in the Tax Court, by when must she file? See 6213.

8. Following up on "7 you researched the law and concluded that the law is favorable to your client in your Circuit, but not in the Claims Court, and that the Tax Court has not yet staked out a position on Ms. Burke's key tax issue. How would your research affect your choice of forum, and, therefore, whether to ignore the 90-day letter?