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QUESTION 1 Why does the former National Taxpayer Advocate criticize the IRS for failing to consider taxpayer compliance contacts through programs and procedures such as
QUESTION 1 Why does the former National Taxpayer Advocate criticize the IRS for failing to consider taxpayer compliance contacts through programs and procedures such as math error corrections, Automated Underreporter (AUR), identity and wage verification, and Automated Substitute for Return (ASFR) are not classified as "real" audits? O a. Taxpayers subject to "unreal" audits are in all instance not entitled to challenge the IRS in court and are bound to adjustments that the IRS makes from these contacts Ob. Taxpayers subject to automated underreporter (AUR) notices are prevented from providing information to the IRS to correct mistakes on the original return and are forced to file amended tax returns to correct an original return that neglected to include all items of income. OC. IRS improperly includes statistics from unreal audits in its annual data analysis of audit coverage and thus overstates its audit rates for individual taxpayers, especially low income taxpayers. d. Taxpayers subject to "unreal" audits are afforded fewer taxpayer rights than taxpayers subject to real audits QUESTION 2 Congress has enacted a new Internal Revenue Code section that provides a refundable credit for the purchase of vehicles authorized under state law to travel on public roads that receive power conversion via an electric motor instead of an engine." The statute does not define vehicle. IRS is planning on issuing guidance under the statute, including providing a definition of vehicle for these purposes. Which of the following statements is accurate in light of IRS rulemaking authority? a. Following Mayo Foundation for Medical and Education Research v United States, if IRS issues a regulation courts will be bound in all instances to accept any regulatory definition of the term vehicle O b. If the IRS issues guidance concerning the term vehicle via a revenue ruling a taxpayer will generally be entitled to rely on that definition so long as there is no subsequent inconsistent legislation or regulations. OC. Following Mayo Foundation for Medical and Education Research v United States, IRS is required to issue all guidance in the form of regulations Od. If the IRS issues guidance concerning the term vehicle in the form of a revenue ruling a court will be bound to accept the definition so long as the definition is reasonable in light of the Mayo Foundation opinion
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